Loss Prevention Handbooks: Automotive Body Shops A U T O M O T I V E B O D Y S H O P S 2 Automobile Body Shops Exposure Abstract Lines of Insurance Areas of Concern Risk* Commercial Automobile Transportation of customers, materials and equipment; towing operations; loaner vehicles provided to customers while their vehicles are being repaired; incidental vehicle use; vehicle theft and vandalism H Liability Slippery surfaces; trip hazards; structural defects; unguarded pits; hazardous tools and equipment; movement of vehicles; inadequate inspection; failure to warn of hazards; inadequate repair; failure to repair; independent contractors; fluid leaks; painting wastes M Property - Crime Employee theft; burglary; fraud L Property - Fire Arson and incendiary fires, faulty electrical and heating equipment, improper storage and use of flammable liquids H Property - Inland Marine / Business Interruption Damage to or loss of equipment, accounts receivables, valuable papers and records, electronic data processing equipment and media, and property in transit; garage keeper’s liability; business interruption M Workers’ Compensation General hazards, hazardous substances, strains, falls L *Risk: L-Low, M-Moderate, H-High Description of Operations Automotive body repair and paint shops are primarily engaged in repairing automotive vehicles damaged in accidents. Automotive body repairers straighten bent bodies, remove dents, and replace crumpled parts that are beyond repair. They repair all types of vehicles but mostly work on cars and small trucks, although some work on large trucks, buses, or tractor-trailers. Some establishments may also do customizing of vehicle interiors and customized painting of automotive vehicle exteriors. While this category generally excludes automotive repair and maintenance services and automotive glass replacement shops, body repairers may perform mechanical and electrical repairs, and replace glass, in the process of performing collision repair work. Automotive body repairers use special equipment to restore damaged metal frames and body sections. Repairers chain or clamp frames and sections to alignment machines that use hydraulic pressure to align damaged components. "Unibody" vehicles, which are designs built without frames, must be restored to precise factory specifications for the vehicle to operate correctly. To do so, repairers use bench systems to make accurate measurements of how much each section is out of alignment and hydraulic machinery to return the vehicle back to its original shape. Body repairers remove badly damaged sections of body panels with a pneumatic metal-cutting gun or by other means and weld in replacement sections. They will also repair less serious dents with a hydraulic jack or hand prying bar, knock them out with pneumatic hammers, or smooth them out using hand tools. They also repair or replace the plastic body parts used increasingly on new model vehicles. Some may specialize in repairing fiberglass car bodies In many shops, automotive painters do the painting. In small shops, workers often do both body repairing and painting. A few body repairers specialize in repairing fiberglass car parts. In large shops, body repairers may specialize in one type of repair, such as frame straightening or door and fender repair. According to a report by the Small Business Research &Information Center of the University of Missouri-Rolla, the 82,471 collision repair shops in the U.S. in 1997 employed 374,684 workers. The average shop employed 7.4 people. About 80 percent of shops are family owned. Just over 2 percent are franchises, according to a 1998 industry profile. The average shop owner is 47 years old and has 24 years of experience. The average shop is about 24 years old and has more than 6,800 square feet in production area. Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S 3 Commercial Automobile Exposure Assessment A variety of vehicles may be employed by an automobile body shop, such as small trucks and towing equipment. To adequately assess the exposure, the extent of the operation needs to be determined. Regardless of the size of the operation, a comprehensive driver qualification, training, and supervision program needs to be in place. Even when employees are using their own vehicles to perform tasks, such as picking up supplies or going to the post office, management should be concerned about their driving skills. Where the automobile body shop is responsible for maintaining their vehicles, adequate maintenance facilities and staff should be provided. The following areas should be reviewed to provide a comprehensive exposure assessment. Operations Are vehicles owned or leased by the business, or do employees use their personal vehicles for business purposes? Are employees allowed to use company-owned vehicles, for personal use? If so, are limitations in place as to who may drive the vehicle and the radius of operation? If passengers are transported in a tow truck, is there a policy in place requiring that they only be transported in actual seating positions with their seat belt properly secured? In the event small children are transported, is the driver required to assure that they are in safety seats? Is there a written safety policy that includes a directive on the safe operation of vehicles? Is a policy in place requiring that all drivers and passengers be secured in a seat belt when the vehicle is in motion? Is there a written policy addressing the consumption of alcohol and illegal substances by all drivers? If State lines are crossed during normal operations, is the business aware of the responsibilities they may be required to meet under the Federal Motor Carrier Safety Regulations? Where the automobile body shop loans a vehicle to a customer whose vehicle is being repaired, is the driver's license and proof of automobile insurance coverage photocopied, and is a written, signed rental agreement executed? Are vehicles that are operated by the business kept in a secure location with adequate key control? Driver Qualification Are drivers properly licensed for the type(s) of vehicle they will operate? Is the operation of vehicles restricted to qualified drivers? Is a driver’s State Motor Vehicle Record obtained when first hired, and periodically updated and reviewed? Do reference checks include information on driving? Are drivers physically qualified to meet job requirements (e.g., securing a vehicle to a tow truck), in addition to driving? Driver Training Are drivers provided the necessary training to drive and work safely, especially where towing operations are involved? Are drivers instructed on how, as well as provided with the equipment (e.g., tie-downs), to properly secure equipment and materials on vehicles? Where towing service is provided by the automobile body shop, is detailed training on the proper securement of vehicles provided to the driver? Are drivers instructed to only use communications devices (e.g., cell phones) when their vehicle is stopped? Are records of driver training documented in the employee’s personnel file? Driver Supervision Are drivers’ work schedules adjusted to limit fatigue and provide for the safe operation of vehicles? Is vehicle routing planned to avoid problem areas, such as roads with restricted weights or low overhead clearances? Vehicle Maintenance and Inspection Are vehicles properly maintained and are maintenance records kept? Are drivers required to inspect vehicles before operation? Emergency Equipment Are vehicles properly equipped with emergency equipment? Are drivers trained in using the emergency equipment? Accident Reporting, Recording and Analysis Are drivers trained on what to do at the scene of an accident? Does management record and analyze each accident to help prevent future occurrences? Liability Exposure Assessment Factors to be considered when evaluating an automobile body shop for liability exposure include: Loss Control Management Does the center have an organized system for managing liability exposures? Do employees receive orientation on their responsibilities under the system? Premises Does the shop have all appropriate licenses and permits? Is the premises secured from unauthorized access? Are parking areas well-lighted and well-maintained? Are customer areas regularly inspected for accident hazards? Are work areas clearly marked and secured from unauthorized access? Are non-employees (e.g., equipment service technicians) escorted when in work areas? Operations Does the shop have procedures for receiving vehicles from outside towing services? Are vehicles awaiting service kept off sidewalks and other public ways? Completed Operations Does the shop maintain current repair manuals and vehicle specifications for the types of vehicles it repairs? Does the shop show evidence of recent and ongoing employee technical training? Are there at least one certified welder and certified painter on staff? Does the shop have the ability to fully hoist a vehicle for inspection? Does the shop have equipment for evaluating the structural alignment of collision-damaged vehicles? Does the shop have equipment for straightening collision damage? Is shop equipment regularly inspected and maintained? Does the shop purchase parts from reputable suppliers? Does the shop have procedures for screening independent contractors used by the shop? Environmental Liability Are shop drains connected to a sewer system or do they discharge to ground water or surface water? Are vehicles stored and serviced on pavement or other low permeability surface? Does the shop maintain an inventory of all hazardous materials onsite? Are hazardous materials stored according to local fire and environmental requirements? Does the shop have good housekeeping practices? Does the shop have an emergency plan for responding to releases of hazardous materials or wastes? Does the shop dispose of its hazardous wastes in a permitted treatment, storage, and disposal facility? Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Property - Crime Exposure Assessment A property crime assessment of an automobile body shop should consider the property crimes of employee theft, burglary, and fraud. Cash and supplies would be subject to theft by employees. Of significant concern is collusion among employees and suppliers to commit acts of fraud, since this can result in significant losses. Tools, equipment, materials, and supplies would be subject to premises burglary and theft. Additionally, as with any retail establishment, vulnerability to credit card, check, and counterfeit currency fraud exists. Employee Theft Are all job applicants thoroughly screened before employment? Are there controls on petty cash disbursements, bank deposits and withdrawals, issuance of checks, payrolls, reconciliation of bank statements, and the paying of invoices? Are there controls on the delivery of materials? Are invoices checked? Are expensive automobile parts and accessories kept in a secure room? Are parts and accessories distributed to repairers by “parts requisition forms” only? This will not only serve to deter theft, but will act as a control on the charges on customers’ bills for parts. Can employees enter or leave the facility without being seen? Is inventory taken on at least on a yearly basis? Can employees who are caught stealing be successfully prosecuted? Burglary Is the business located in a high-crime area? The local police should be able to provide statistics on property crime and, in particular, burglary for the area. Would it be easy for a burglar to gain entry? Burglars have no regard for private property and will be as destructive as necessary to break in and obtain cash or valuable items. They will readily cause hundreds, even thousands, of dollars worth of damages in order to commit the crime. Is the exterior of the building properly illuminated? Are exterior lighting fixtures protected against breakage, and are damaged lighting fixtures or burned-out bulbs replaced as soon as possible? Is cash deposited in the bank on a regular basis and/or secured in a burglary-resistant safe? Theft Are yard storage areas protected by a fence? Are yard storage areas adequately illuminated? Are vehicles in yard storage areas locked and the keys placed in a secure location? Fraud Is there a policy regarding the acceptance of payment by checks or credit cards? Is the policy posted near all cash registers? Are clerks trained in the company’s policy regarding acceptance of checks and credit cards? Are clerks trained in identifying counterfeit currency? Property - Fire Exposure Assessment The fire exposures for automobile body shops will vary based on the type of construction, the size of the facility, the activities performed, and the equipment used. Buildings, tools, equipment, materials, and supplies of automobile body shops are subject to loss during a fire. Fires may be suspicious or incendiary in nature, electrical in origin, or caused by faulty heating equipment. The presence of flammable and combustible liquids significantly increases the fire loss potential. 4 Facility Design and Construction Is the facility in compliance with local building and fire prevention codes? What is the date of the last inspection of the facility by the local fire department? Have any renovations and/or alterations been made since the inspection? Are there fire exposures from adjacent buildings or structures? Are boiler rooms and storage rooms separated from each other and all other spaces by firewalls or fire barriers? Are fire exits readily accessible? Are concealed spaces in attics properly fire stopped, or otherwise protected? Are the building’s furnishings and decorations fire retardant? Are high-hazard areas, such as paint spraying and paint mixing areas, separated from each other and all other spaces by firewalls or fire barriers? Are paint mixing rooms limited to a total floor space not exceeding 150 ft2 (14 m2) and provided with spill containment? Is the facility located in building that is separate from assembly, educational, and residential occupancies? Utilities Are electrical appliances used where flammable atmospheres are present listed/approved for use in these areas? Is electrical equipment located adjacent to spray booths approved for Class 1, Division 2 use? Are electrical heating devices used for paint drying areas provided with over-temperature limit protection? Does the electrical system appear to be in good working condition? Is electrical equipment used in wet areas, such as restrooms and vehicle wash areas, designed to provide ground fault protection, including the use of isolated power supplies. Is gas- and oil-fired equipment maintained following the manufacturers’ recommendations? Is the electrical system adequate to handle the expected loads? Storage Areas Are accumulations of combustible materials, such as rags, paper supplies, and records, stored in an area separated by firewalls or barriers? Are flammable liquids stored in containers that are listed/approved by a nationally recognized testing laboratory, such as Underwriters Laboratories Inc. (UL)? Are paint storage rooms equipped with ventilation equipment designed to maintain a constant flow of air to prevent the buildup of flammable vapors? Fire Suppression and Alarm Systems Is the building protected by an alarm system that provides both manual and automatic initiation devices? Does the building have a sprinkler system that is installed and maintained in conformance with NFPA 13, Standard for Installation of Sprinkler Systems, published by the National Fire Protection Association (NFPA)? Are sprinkler heads located in paint spray areas protected form over-spray? Is the facility equipped with a fire detection system? Are portable fire extinguishers provided? Are employees trained in their use? Operations Is smoking allowed on the premises? If yes, is it restricted to certain areas? Is a hot-work permit system used for all cutting, welding, and soldering operations? Are equipment-cleaning operations using flammable or combustible liquids conducted in well-ventilated areas, away from open flames and other ignition sources? Is the use of chlorinated solvents in paint spraying areas and equipment prohibited? Is proper bonding/grounding of container provided before transferring flammable liquids into portable containers or equipment fuel tanks? Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Is the heating system for paint drying interlocked with the spraying equipment so that no spray operations can be performed while the heating system is active? Is the paint spray ventilation system designed and monitored to ensure that flammable vapor concentrations do not exceed 25percent of the lower explosive limit (LEL)? Emergency Preparedness Is there an emergency action plan for the facility? Are emergency evacuation drills conducted on a semi-annual basis? Do employees check the exit doors and exit paths on a daily basis to ensure access during an emergency? Incendiarism and Arson Does a fence protect the perimeter of the property? Are all exterior areas of the property illuminated? Are exterior doors and windows secured from un-authorized access? Property - Inland Marine Exposure Assessment The following areas should be reviewed in order to assess the inland marine exposures of an automobile body shop: Equipment What are the ages, condition, numbers, and types of equipment that could be exposed to loss? Are there permanent identification markings on all specialized or high-value equipment? Are there sign-out sheets for parts and equipment, and are records kept on file? What equipment is owned, rented, or leased? Are there service contracts on the equipment in case of mechanical breakdowns? Is there an inventory control program for equipment? Are essential replacement parts for vital equipment kept on the premises? Is inventory taken on a regular basis? Is the equipment and body shop secured against theft? Is any equipment stored outside? Is there more than one storage location for equipment? Is the equipment kept clean, well maintained, and in good working order? Is a routine maintenance program in place? Is any equipment stored outside? Garage Keepers’ Legal Liability Are vehicles stored in a safe location? Are all employees trained in proper key control methods? Are all vehicles checked to be sure that no keys are left in the vehicle during off-hours? Are all keys off vehicles left overnight placed in a lockbox and stored in a secure location? If repairs are subcontracted out, has the qualifications and reputation of the subcontractor been checked? Are procedures in place to limit the possibility that a vehicle will not be returned to the original owner? Have subcontractor’s “Indemnification and Hold Harmless” agreements been signed? Are customers advised to remove items of value from inside the vehicle? Are signs posted indicating that the body shop is not responsible for any articles left in the vehicle while being repaired? Are parking areas for customer-owned vehicles provided with security cameras? Are parking areas for customer-owned vehicles fenced in and well lit at night? Does a security service patrol the area at night? Does the auto body shop offer towing services? 5 Accounts Receivable Is there a well-organized and supervised bookkeeping system in place? Are there general procedural controls to protect records? Are there accurate and complete records of work performed for every repaired vehicle? Does the shop provide a secondary service, such as parts and accessories, state auto inspections, or towing? Are smoking regulations for both employees and customers enforced? Is the property protected by automatic sprinklers and smoke detectors? Is the fire alarm system connected to a central station monitoring service? Is good housekeeping practices maintained as a means of controlling fire hazards? What is the financial condition of the business? Has there been a decline in business in recent years? Are outside audits of financial records conducted on a yearly basis? Are there contingency plans in place to retrieve and recover damaged records? Valuable Papers/Records Is there risk of theft, arson, or vandalism, or for water or flood damage? Are valuable papers/records stored in appropriate record protection equipment? Are good housekeeping practices maintained throughout the facility? Is the facility protected by an automatic sprinkler system and smoke detectors? Is there a fire alarm system and is it connected to a central station monitoring service? Business Interruption What is the history of natural hazards, such as flooding, hurricanes, tornadoes, and lightning, in the area? What is the potential for any of these events closing the shop? Is the shop protected by an automatic sprinkler system that meets applicable codes and standards? Does the shop operate independently or is it part of a national chain, such that a temporary business interruption could be handled by another shop in the chain? Are the premises owned or leased? Does the shop subcontract any of its work to other body shops? Is the operation a franchise shop specializing in specific types of auto body repair? Is the shop in a stand-alone building or is it located in a strip mall, such that a fire in adjoining premises could spread to the shop? What is the financial condition of the automobile body shop? Has there been a decline in business in recent years? Is there potential for arson? Does the shop have one essential manufacturer for specialized equipment or replacement parts? Does the shop experience a peak season? What would be the effect if a loss occurred during the peak season? What is the experience and training of the workers? What are the usual hours of operation and number of employees? Electronic Data Processing (EDP) Equipment and Media What are the ages, number of, and condition of all type computers, fax and copy machines, and other special equipment at the shop? Is there any custom-made software in use? Does the shop have computerized accounting, recordkeeping, or inventory control systems? Are backup files for such systems kept in a fire-resistant safe or stored at an off-site location and backed up on a regular basis? Is the system for repair estimates computerized? Where is specialized equipment stored? Property in Transit What modes of transportation are used? What is the frequency and maximum distances traveled? Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S What is the average maximum value of the property in transit? Does the shop manage its own fleet of vehicles?? What is the frequency of shipments? Are long hauls made on a regular or occasional basis? What is the maximum value of the shipments? Are vehicles in transit subject to theft or hijacking because of their value? What procedures are followed when vehicles are left unattended? Signs and Awnings Is each type sign and awning described in detail, indicating the age, type of material, description of the size and type of lettering, and their location on the facility? How are the signs and awnings constructed, at what height from street level are they located, and how are they fixed to the structure? Are signs attached or of the freestanding type? Are outside signs and awnings subject to fire, hail, windstorms, vandalism, or damage from moving vehicles? Workers’ Compensation Exposure Assessment For automobile body shop workers, an assessment of exposures to injuries and illnesses should focus on general hazards, hazardous substances, strain, and falls. However, in analyzing the level of safety for any organization, consideration should be given to management’s concern and actions in establishing safe work procedures, and workers’ involvement in creating a safe work environment. Management Is there a formal and written safety program? Is there an understanding of the financial impact of losses/injuries on the bottom line? Is there a safety orientation and training program for new workers? Are healthcare and/or other benefit programs made available to all workers? What are the ages, training, and experience of the workers? Is there high turnover? Are less-experienced workers properly supervised? Are new workers required to take pre-employment physicals? What is the historical frequency and severity of workers’ compensation claims? Are on-site medical services provided? Has the company ever been cited for safety deficiencies by Federal or State agencies? Is personal protective equipment (PPE) provided to workers? General Hazards Is PPE, such as safety shoes, gloves, and safety glasses and goggles, provided and used when operating equipment and tools? Is a maintenance program established to assure the safe operating condition of PPE? Is the point-of-operation of equipment (e.g., air compressors, bench grinders, and chippers) provided with safety guards? Is a training program established to ensure the safe operation of vehicle lifts, welders, chisels, grinders, jacks, compressed air equipment, and tire changing equipment? Is a training program established to ensure the safe handling of glass? Are all pieces of equipment with an electric motor or any electrical connections effectively grounded to limit the risk of shock or electrocution? Are all points of power transmission equipment (e.g., belts and pulleys on motors, compressors, rotating shafts, sprockets, and gears) properly guarded? Is there a maintenance program to ensure that tools, such as chisels and punches, with mushroomed heads have been replaced? 6 To limit the potential for explosions and resultant injuries, are stored gas and oxygen cylinders separated by 20 ft (6.0960 m) or a barrier 5 ft (1.5240 m) high? Hazardous Substances What hazardous chemicals are stored, handled, or used by workers? Are Material Safety Data Sheets (MSDSs) obtained and made available to workers? Are all workers able to read the MSDS and understand the hazards and safety requirements? Are hazardous chemicals properly labeled? Are workers trained according to the requirements of the OSHA Hazard Communication Standard? Is personal protective equipment (PPE) provided for workers who use or handle chemicals? Are chemically-soiled materials and equipment either sterilized or discarded? Are any carcinogenic chemicals used in the school science department? Is the exhaust ventilation system adequate to remove flammable/toxic vapors in the science department? Are flammable and combustible liquids stored in approved containers? Are waste removal procedures for chemicals established? Are emergency overhead showers and eye wash stations provided? Strains Are workers instructed in the use of safe-lifting techniques? Are workers encouraged to obtain help when lifting or moving heavy objects? Are procedures for two-person lifts used, where appropriate? Are back injuries investigated to determine the causes and identify needed procedural changes? Falls Is slip-resistant flooring or mats used in appropriate locations? Are all areas kept neat and orderly to prevent same-level slips, trips, and falls? Are warning signs used during and after a floor has been mopped or waxed? Is adequate lighting provided in aisles, stairways, and storage rooms? Are good-housekeeping procedures emphasized? Is trash removed on a daily basis? Are worn, torn, or loose flooring immediately repaired? Are wiring and telephone cords properly secured to prevent tripping hazards? Is a snow removal and salting program provided for parking lots and side walks during winter months? Commercial Automobile Exposure Controls A loss control program to address the commercial vehicle exposures of an automobile body shop should include the following factors: operations; driver qualification, training, and supervision; emergency equipment; vehicle maintenance; and accident reporting, recording, and analysis. Operations Scope of Operations - The majority of automobile body shops will have a limited number of vehicles. However, some will provide towing service, loaner cars, or transportation for their customers. These varied exposures require different levels of management attention. However, all company drivers need to be evaluated on their ability to operate a vehicle. Employees will frequently move customer's vehicles for repair purposes and may test-drive them. Automobile body shops may provide their own towing service to pick-up customer's vehicles. Towing service for vehicles involved in accidents can result in drivers going to unfamiliar areas with increased risks getting to and working at an accident scene. Towing vehicles should be adequately sized for the vehicles they will be moving, Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S and appropriately licensed and insured for their intended use (state regulations may vary). Drivers may also be required to provide service under very inclement weather conditions. Downtown commercial areas with their narrow streets, traffic congestion, and high volume of pedestrians create significant exposures. In residential areas, there may be increased risk from children playing in the street and other pedestrians in the area. Safety Policy - It is essential that the employees of the automobile body shop be instructed that the safe operation of vehicles is extremely important. This directive commonly takes the form of a safety policy that states management's concern with safe operations, including vehicular safety. The policy statement should be signed by the owner/president of the company and be well publicized throughout the organization. All personnel should be held accountable for deviations in safe practices. As management sets the example for their employees, it is imperative that they adhere to the safety policy at all times. For further information, see Commercial Vehicle Report CV-10-04, Safety Policy. Employee Vehicles - Even when an employee is using their own vehicle to perform tasks, such as picking up parts or going to the post office, management should be concerned about their driving skills. An up-to-date copy of ‘proof of insurance’ for the employee’s vehicle, preferably with the liability limits of the policy, should be kept on file in the event an accident occurs. Driving - Management should insist that drivers and any passengers be secured in a seatbelt whenever a vehicle is in motion. Drivers taking medications should be aware of their side effects, and decline to drive a vehicle if they have any concerns about adverse reactions to the medication. Drivers should take steps to minimize distractions while driving. The use of cellular phones, two-way radios, and other communication devices should be prohibited when the vehicle is in motion. Crossing State Lines - Where an auto body shop's vehicles cross state lines, in vehicles with a gross vehicle weight rating of 10,001lb (4,537 kg) or more, the garden center is required to comply with the Federal Motor Carrier Safety Regulations (FMCSR) of the Department of Transportation’s (DOT), Federal Motor Carrier Safety Administration. Substance Abuse - The consumption of alcohol should be prohibited for drivers anytime during working hours and for four hours prior to driving. A policy should also prohibit the use of controlled substances. Loaner Vehicles - When automobile body shops arrange for loaner vehicles for their customers, procedures need to be taken to reduce the business's loss exposure. Where feasible, it is better for the automobile body shop to arrange to provide a loaner vehicle through a reputable car rental service. If the loaner vehicle is owned by the automobile body shop, the shop should have a written contract with the customer stipulating who provides the primary insurance and any restrictions on the use of the vehicle, such as radius of operation and who can drive the vehicle. A photocopy of the customer's driver's license and proof of insurance should be made. Loaner vehicles should be inspected before the customer takes the vehicle, and when it is returned. Vehicles should be well maintained and detailed maintenance records kept on file. Security - To prevent theft, vehicles should be locked when unoccupied and alarm systems activated, if provided. Keys to vehicles should be controlled and in a secure location, and adequate lighting and other crime prevention precautions should be taken at the auto body shop. Driver Qualification Establishing Policy - The establishment of a meaningful and realistic driver qualification program is vitally important to the safe operation of a business's vehicles. The employer should determine exactly what tasks will be required of the employee, how they will be accomplished, and what skills are required. Automobile body shop's operating vehicles with a gross vehicle weight rating over 10,000lb (4,536kg) between states are also subject to the requirements of the FMCSR. Employees with Disabilities - Auto body shops should also determine standards for the "essential functions" necessary to complete the job in order to determine whether an individual with a disability would be qualified, with or without "reasonable accommodation." Standards can be physical (i.e., ability to repeatedly lift materials weighing up to 60lb (27kg) out of trucks), or based on degrees of experience or specific skills required. It is imperative that these standards are for essential functions 7 necessary to perform the job and be applied equally to all applicants for the position, as required by the Americans with Disabilities Act (ADA). For information on the ADA, see Liability Reports LB-70-20, The Americans with Disabilities Act – ADA, and LB-70-21, Americans with Disabilities Act – Hiring Practices. Driver Licensing - The type and size of the vehicles operated by the business will determine the type of driver’s license required by operators. While States regulate the minimum licensing requirements of all drivers, drivers of vehicles that have a gross vehicle weight rating (GVWR) greater than 26,000lb (11,793kg), must have a Commercial Driver’s License (CDL). Under the CDL program, a driver must hold a single license from his/her State of domicile, and the State issuing the license must maintain a single Motor Vehicle Record (MVR) on the driver. Driver History - A driver’s application for employment should require information on driving history. A copy of the applicant’s Motor Vehicle Record (MVR) should be obtained from each state where a driver holds a license to ascertain that the applicant has a valid license and to review the driver's past record. While a driver required to have a CDL can only be licensed in one state, other drivers will sometimes obtain multiple state licenses to spread violations. A history of accidents and moving traffic violations could indicate a major problem with an applicant. An MVR also should be obtained periodically for each driver and reviewed to determine whether remedial training is necessary. This review may give the supervisor insight as to the driver's attitude regarding traffic rules and regulations. Reference checks should include information on the ability and experience of the potential employee in the operation of vehicles. Information should include the types of vehicles and frequency of operation. Driver Testing - A qualified driver should take a test drive with the employee/applicant to determine if there are any deficiencies in driving skills and to evaluate defensive-driving techniques. Defensive driving is driving to prevent accidents in spite of the incorrect actions of others or adverse driving conditions (such as weather, traffic, lighting, vehicle or road conditions, or the driver's physical or mental state). Any bad driving habits should be corrected prior to a driver's first trip. Driver Qualification File - A copy of the driver’s license and current MVR, and information on reference checks, road testing, and training, should be made part of the driver/employee personnel file. Automobile body shops that are subject to the requirements of the FMCSR must maintain a driver qualification file with specific information. Drug Testing - All drivers holding a CDL must be included in a drugtesting program meeting the requirements of the DOT. Including all drivers and maintenance personnel in this program is advisable; however legal counsel should be consulted before instituting the program. For further information, see Commercial Vehicle Reports CV-20-00, Driver Qualification; and CV-50-04, Controlled Substances and Alcohol Use and Testing; CV-50-06, Commercial Driver’s License; and CV-90-09, Driver Qualification Files for Interstate Motor Carriers. Physical Qualifications - The physical fitness of the driver should be considered before hiring, but only after the driver has been offered a job. The motor carrier should arrange for physical examinations, with individual physicians or industrial clinics. The medical examiner should be aware of the physical and emotional demands placed on the driver as well as the requirements of the job, so that it can be determined whether the applicant is qualified for the position. In addition to checking a driver's physical condition before hiring, periodic physical examinations should be required and arranged for by the automobile body shop. Reexaminations may indicate the onset of a problem and therefore allow appropriate corrective measures to be taken. Physical qualifications should be carefully considered to avoid discriminating against a qualified disabled applicant under the Americans with Disabilities Act (ADA). The employer should determine if the applicant will pose a "direct threat" to health or safety as a result of a physical condition, and should also consider if the physical problem could be eliminated or reduced below the level of a "direct threat" by reasonable accommodation. While Federally mandated physical standards do not appear to be preempted by the ADA regulations, state (even when adopting the Federal requirements) and individual company requirements might be subject to close scrutiny, to assure that they do not discriminate against the disabled. Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Driver Training Benefits - Proper training reduces operational disruptions and minimizes unnecessary costs from accidents and equipment abuse. Positive driver attitudes can be promoted by emphasizing that the intent of the training program is to benefit drivers by helping them to perform their jobs safely and efficiently. Trainers - The person selected to do driver training should have an unblemished personnel and safety record (to serve as an example for others) and sufficient experience to have knowledge of the auto body shop’s operations and procedures. Training - The driver-training program needs to address the areas that a driver will face in the course of day-to-day operations, as well as unusual or emergency situations that may occur. Special controls (e.g., tow truck controls) should be demonstrated, and the driver should be instructed in the way to make a proper vehicle inspection. Drivers of towing vehicles should be thoroughly trained on the proper securement of vehicles. Documentation - All training should be documented in the driver's qualification file, including the type of training and date. Having the driver sign a form verifying that training was received is a good policy. Emergency Procedures - Emergency procedures should be established to deal with problems encountered while en route. In case of mechanical problems with the vehicle, the driver should know what to do with the disabled vehicle, the proper placement of emergency warning devices, and the person(s) to contact for repairs. For further information, see Commercial Vehicle Report CV-25-00, Driver Training. Driver Supervision Guidelines - One of the critical elements for a successful driver supervision program is the establishment of specific guidelines for job performance. These guidelines should be clearly understood by both supervisors and drivers, and applied equally to all drivers. Scheduling - Fatigue can have a severe effect on the ability of a driver to operate a vehicle safely and schedules should be carefully assessed to help assure that the driver has sufficient rest. Driver Observation - Direct observation by following the driver, as well as providing a clearly displayed toll-free telephone number to file a report on the driver, are techniques to help assure that the driver is adhering to company policy and driving safely. For further information, see Commercial Vehicle Report CV-30-00, Driver Supervision. Vehicle Maintenance and Inspection Accountability - Reduced operational costs, reduced accidents from vehicle defects, and improved public opinion are direct benefits of a well-implemented maintenance policy. Drivers, maintenance personnel, and supervisors should be held accountable for the condition of vehicles, and clear lines of communication need to be established between them. Pre-Trip Inspection - Operators should have their drivers perform a pre-trip vehicle inspection on each vehicle operated to discover any defect or deficiency that would affect the safe operation of the vehicle or result in its mechanical breakdown. The inspection should cover at least the following parts and accessories: service brakes; parking (hand) brake; steering mechanism; lighting devices and reflectors; tires; horn; windshield wipers; rear vision mirrors; towing devices; wheels and rims; and emergency equipment. A vehicle with a known safety defect should not be allowed on the road until repairs have been completed. Placing an out-of-service tag or similar identifier on the vehicle can help to highlight that the vehicle is unavailable for use. Automobile body shops required to comply with the FMCSR must have its drivers complete a pre- and post-trip inspection report and also require that the motor carrier or its agent certify on the original driver vehicle inspection report that any listed defect or deficiency has been repaired, or that repair is unnecessary, before the vehicle is operated again. Before driving a motor vehicle, the driver must: be satisfied that the motor vehicle is in safe operating condition; review the last driver vehicle inspection report; and sign the report if defects or deficiencies were noted by the driver who prepared the report, to acknowledge that the driver has reviewed it and that there is a certification that the required repairs have been performed. Vehicle Maintenance - Auto body shops performing their own vehicle maintenance should assure that they have adequate facilities and 8 qualified mechanics. Vendors providing vehicle maintenance should be qualified to perform the work and be reputable. When vehicles are leased, it should be clearly stated who is responsible for providing maintenance. The schedule for performing vehicle maintenance should be detailed and performed accordingly. A good maintenance program should include a thorough and up-to-date recordkeeping system. To be useful, maintenance records should: clearly identify the vehicle; be kept current; only record meaningful data; and be reviewed on a periodic basis. Employee-Owned Vehicles - Automobile body shops using employeeowned vehicles need to be concerned with the condition of those vehicles as well. A poorly maintained, employee-owned vehicle that is involved in an accident, while on company business, can result in liability for the auto body shop. For further information, see Commercial Vehicle Report CV-35-00, Vehicle Maintenance. Emergency Equipment Training - All vehicles should be provided with emergency equipment, both as an aid in preventing accidents and to assist other motorists by alerting them of potential problems. The best emergency equipment available is of no value unless the driver has been instructed in its proper use. Equipment - A fire extinguisher should be provided on every vehicle, and be securely mounted and located so that it is readily accessible for use. There should be at least one spare fuse or other overload protective device for each kind and size required for the vehicle, unless devices used are of the reset type. To alert other drivers in the event that a vehicle is obstructing the roadway, it is recommended that vehicles be equipped with three bi-directional emergency reflective triangles. A set of tire chains, for at least one driving wheel on each side of a drive axle, should be standard equipment during the time a truck is likely to encounter conditions requiring them. Drivers should be thoroughly instructed in the proper installation of the tire chains. Wheel chocks, while not usually considered emergency equipment, should be carried on trucks for use on inclines, and as safety devices at service areas, unless the truck is equipped with spring brakes that automatically engage when the unit is parked. Equipment should be carried on tow trucks (e.g., broom and absorbent material) to clear debris off the roadway. For further information, see Commercial Vehicle Report CV-40-00, Emergency Equipment. Accident Reporting, Recording and Analysis Preparedness - A system of reporting, recording, and analyzing the facts surrounding vehicular accidents should be established. Those involved should know their role should an accident occur, and procedures should be in place to provide for a thorough analysis of the events that led up to the accident. The initial actions at an accident scene are often critical to the outcome of the incident. The driver may be under extreme stress at the time; thus the procedures to follow should be clear and concise, and thoroughly understood. An information packet containing instructions and forms for use in case of an accident should be carried in the vehicle at all times. After protecting the accident scene and assisting anyone that was injured in the accident, the first step in accident reporting is for the auto body shop's driver to collect all pertinent information at the scene and include it in a preliminary accident report. Thoroughness in performing this task will be of great help in assessing the accident afterwards. Once the driver has obtained the basic information for the preliminary accident report, management should be contacted. Management Investigation - All accidents should be investigated to some extent. Management needs to know exactly what happened and why it happened in order to determine what might be done to prevent a similar occurrence in the future. A determination should be made as to whether the accident was a "preventable accident" on the part of the auto body shop's driver. This is irrespective of the legal conditions surrounding the accident, as preventability relates to "defensive driving" and not legal culpability. A preventable accident is one in which the driver failed to exercise every reasonable precaution to prevent the accident. In order to avoid becoming involved in a preventable accident, it is necessary for a driver to understand the concept of, and to practice, defensive driving. Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Accident Analysis - The investigation of each accident should not merely seek the specific act that was involved, but should go further into the conditions responsible to avoid problems in the future. The investigation should include the following areas: • Checking the driver's record for similar occurrences, length of service, and indications of poor attitude or lack of skill. • Questioning whether a proper job of selection was done, whether training was adequate, and if the driver was properly supervised. • Determining if there were previous indications that should have warned of an impending accident. • Ascertaining if there was any indication of improper maintenance procedures or if an equipment deficiency was involved. Thorough analysis of the accident may indicate that remedial training or disciplinary action of the driver is necessary, or that operating procedures need to be modified. Accident Register: All vehicle accidents should be recorded, in chronological order, in an "accident register," to provide management with an overall summary. Analyzing the accident register may indicate problem areas or trends that would not otherwise be obvious by reviewing accident reports separately. The accident register should include at least the following information: date of the accident; name of the driver; vehicle Identification number(s); location of the accident; a brief description of the accident; the number of fatalities; the number of injuries; and the amount of property damage. For further information, see Commercial Vehicle Reports CV-25-01, Accident Procedures; CV-45-00, Accident Reporting, Recording, and Analysis; and CV-45-01, Determining the Preventability of Motor Vehicle Accidents. Liability Exposure Controls The following sections provide recommendations for controlling loss exposures that typically occur at automobile body shops. Loss Control Management The facility should develop and implement an organized system for managing liability loss exposures. The system should define the policies and procedures that the organization will take to eliminate or control potential liability loss exposures. The formality of the program will vary depending upon the size of the business; however, the system should include provisions for regular inspection of the premises for loss exposures; documentation of inspection results and corrective actions taken, if any; accident reporting and investigation; loss analysis; and plan auditing. Employees should receive orientation in their responsibilities under the program when first hired. Retraining should be provided on a regular basis. For further information on developing loss control management systems, see Liability Report LB-20-01, Loss Control Management System. Condition of the Premises General - Body shops should take steps to ensure that those areas of the premises accessible to customers and other non-employees (e.g., delivery personnel) are reasonably safe. These steps should include (1) meeting applicable public safety codes and standards (e.g., building and fire codes); (2) regularly maintaining the premises; (3) inspecting the premises for accident hazards; and (4) addressing any hazards that are identified (e.g., by correcting the hazardous condition or warning others of the hazard). Perimeter Security - Body shops should secure the perimeter of the premises to prevent unauthorized public access. Additional steps may be necessary to prevent crime. The method of securing the premises will vary depending upon the characteristics of the premises. If the shop facilities are set back from the public way, chain link fencing or other barricading may be used. If the shop abuts a public way, the building walls themselves may serve to restrict access. In these cases, any accessible windows or doors should be secured. All perimeter security should be regularly inspected and maintained. Signs should be posted warning trespassers of any potentially hazardous security measures employed by the operator, such as guard dog or armed 9 guards. Also, security personnel should be properly screened, trained, and supervised. For additional information on access restrictions associated with crime prevention, see the Property -Crime Exposure Controls section of this report. Fire Safety - Body shops should take steps to prevent fires. Such steps should include complying with local building and fire code requirements for the design and operation of paint spray booths and vehicle repair areas, safely storing and handling hazardous materials, preventing the accumulation of painting wastes and other combustible debris, and emergency planning. For detailed information on fire protection, see the Property - Fire Exposure Control section of this report. Lighting - Lighting should comply with local building and fire code requirements. If no code requirements are specified, lighting should meet the guidelines of the Illuminating Engineering Society of North America (IESNA). Lighting should be inspected regularly and burned-out bulbs should be replaced on a timely basis. Electrical wiring to fixtures should not be exposed, and lighting fixtures should be protected from vandalism. Outdoor lights should be able to withstand the elements. Emergency lighting should be installed wherever required and regularly tested. Parking Areas - Body shops should have clearly identified visitor-parking areas. The parking area should be well-lighted and well-maintained. Drainage should be provided. Gratings, posts, or other obstructions, or changes of surface, should be clearly marked. The parking lot should be posted with signs or markings indicating where vehicles are to travel. The markings should be easily visible and understandable. Sidewalks should meet local building code requirements and should not be obstructed with garbage or other debris. Exterior ramps or stairs leading to visitor entrances should meet building code requirements, be well maintained, and be regularly inspected for accident hazards (e.g., worn nosing, obstructions, ice, or snow). Waiting Areas - Shops should provide areas where customers can wait while their vehicles are being inspected or repaired. These areas, and other areas accessible to non-employees (e.g., bathrooms and office areas), should be clearly identified. They should be regularly inspected for accident hazards, such as torn carpet, spilled liquids, floor level obstructions, broken furniture, and damaged appliances or electrical equipment. Hazards that are identified should be corrected or other steps taken to warn or mitigate the hazard. Hazardous equipment and materials should not be stored in customer areas. Means of Egress - Means of egress should be clearly identified. Every exit should be clearly visible and the route to the exit conspicuously indicated. Exit access and exits themselves should be marked and lighted, as required by local code. Employee Areas - Shop areas that are restricted to employees should be separated by doorways, barricades, or other access control devices. Restricted areas should be clearly marked. Non-employees should not be allowed in these areas unless they are escorted and are wearing appropriate protective equipment, such as safety shoes and protective eyewear. The escort should warn the visitor of latent hazards that they are aware of. Visitors should not be allowed in areas where hazardous operations are being performed until after the operation has been completed and the area secured. Tools, equipment, and supplies should be secured to prevent unauthorized use. Delivery Areas - Shops that receive regular deliveries of parts and supplies should have designated areas where delivery personnel may load and unload shipments. These areas should be away from service areas where hazardous operations are performed. The location should be marked and delivery services made aware of the location. Safe egress should be provided to these areas and the area should be inspected for accident hazards. Vehicle Drop-off Areas - Shops that accept delivery of vehicles during off-hours should have a designated area where customers or towing services can leave vehicles. Shops should post signs indicating where such areas are. The area should be well-lighted, well-maintained, and inspected regularly for spilled automotive fluids or other hazards. Any hazards identified should be addressed in a timely manner. Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Operations Inspections and Repairs - Vehicle inspections and repairs should be performed in areas that are restricted to employees. Repairs should not be performed on sidewalks or other public ways. Safe work practices should be followed. See the Occupational Safety section of this report for further information on safe work practices at body shops. Towing Services - Shops should establish procedures for receiving vehicles from outside towing services. These procedures should be posted at the entrance to the loading area. Safety precautions should be clearly identified. Shop employees should supervise all vehicle drop-offs during business hours. Test Drives - Employees may need to test drive a customer’s vehicle to diagnose a problem, check on the quality of a repair, or pick-up or deliver the vehicle to the customer. Shops should consider the use of dynometers or other stationary testing equipment to reduce the need for road testing vehicles. Also, shops should take steps to ensure that drivers are qualified and are capable of operating a vehicle safely. See the Commercial Vehicle section of this report for further information. Independent Contractors - Independent contractors may be used for pest control, security services, equipment maintenance, or a variety of other operations. Liability exposures created by the use of independent contractors can be managed through contractor selection, contractual agreements, and certificates of insurance. Once on-site, the contractors should be made familiar with the shop’s safety policies. Completed Operations Training and Certification - Shops should ensure that technicians hired by the shop have appropriate skills for the work that they perform. Shops should make inquires about the qualifications of all prospective employees in the employment application. All references should be verified. Many high schools, vocational schools, private trade schools, and community colleges offer training programs in automotive body repair. The two primary organizations that certify training programs are the National Automotive Technicians Educational Foundation (NATEF), an affiliate of the National Institute for Automotive Service Excellence (ASE), and the Accrediting Commission of Career Schools and Colleges of Technology (ACCSCT). SKILLS-USA/VICA provides a directory of public auto body repair training programs. The Collision Industry Conference (CIC) has developed skill recommendations for various levels of skilled employees. The National Institute for Automotive Service Excellence (ASE) is the most widely recognized developer of certification requirements for collision repair and refinish technicians. ASE offers three levels of certification, ASE Collision Repair or Refinishing Technician, ASE Master Collision Repair/Refinishing Technician, and ASE Collision Damage Estimator. Certifications are obtained through meeting minimum experience requirements and passing certification exams. Technicians must retake examinations at least every five years in order to maintain their certifications. The Inter-Industry Conference on Collision Auto Repair (I-CAR) is a widely recognized developer of skills training programs for the collision repair industry. I-CAR courses cover a broad range of topics from understanding collision repair to advanced vehicle systems. Vehicle manufacturers, paint manufacturers, equipment providers, or other parts suppliers may offer training in the use or repair of their products. Technicians that perform specialized tasks, such as painting or welding, may require additional certifications in order to meet regulatory, franchise, or insurance company requirements. These certifications may be provided by the manufacturer of the product, the vehicle manufacturer, or a third-party certification organization, such as the American Welding Society. Shops should provide regular or refresher training to employees. This is important for maintaining the skill level of the employees. New automobile design and manufacturing trends, including unibody construction and the increased use of plastics and composites, have changed the way repairs must be performed on certain vehicles. In addition, the use of advanced electronic systems in vehicles provides greater chance for damage by improper repair techniques. Tools and Equipment - Shops should have the necessary tools and equipment to perform the services they provide (e.g., structural repair, non-structural repair, and painting). This equipment should be 1 0 maintained in good operating condition. Shops should maintain all instruction, service, and operating manuals for the tools and equipment that they use. All operators should be trained in the proper use of the equipment. The CIC requirements for a “Class A” collision repair shop specify that a collision repair shop should have certain basic equipment. This includes: (1) A method of fully hoisting a vehicle so that the undercarriage of the vehicle may be inspected for damage. Overhead lifts are typically used for this task, although drive over pits may be used in older shops. (2) Equipment for evaluating the structural alignment of collision-damaged vehicles. Typical equipment may include tram and centerline gauges, tape measures, lasers, and computerized systems. Shops that repair unibody structures should have equipment capable of making measurements in three dimensions. (3) Equipment for making body or structural pulls and a suitable anchoring system for holding the vehicle stationary during the pulls. (4) Welding equipment for repairing damaged metal. Metal Inert Gas (MIG) and Gas Metal Arc (GMA) welding are the most common types of welding equipment used. (5) Shops should have access to equipment for evaluating four-wheel alignment. This equipment may be owned by the shop or by a subcontractor who performs the work for the shop. Printouts should be kept with the customer file. Vehicle Information - Shops should have service manuals, dimension data and paint manuals, and documentation for all vehicles that they service. These manuals should be maintained up to date. Body shops should maintain all manuals, installation instructions, and documentation for all aftermarket parts used. Vehicle Inspections and Repairs - All work should be performed according to manufacturer recommendations or industry best practices. Several organizations within the collision repair industry (e.g., ASA, CIC, and I-CAR) have established standards of practice for performing inspections and repairs. In addition, specific part or component suppliers, such as paint manufacturers, may provide specific instructions for using their products. Parts - Service estimates should be prepared in writing and should identify the parts and materials to be used for the job. Parts should be appropriate for the service being performed and purchased from reputable suppliers. All parts should be inspected prior to installation, with particular attention paid to the condition of salvaged or aftermarket parts. Shops should keep copies of all guarantees and warranties provided by part manufacturers. All parts substitutions should be noted. Supervision - The work of all lesser skilled or new employees should be overseen by a more experienced technician. All completed work should be reviewed by a senior technician before the vehicle is returned to the customer. Contracted Work - Shops should establish procedures for addressing liability exposures from work, such as wheel alignments, that are performed by third-party subcontractors. These procedures should include requirements for contractor selection, the use of indemnification or hold harmless agreements, and certificates of insurance. Warnings - Shops should inform the customer of any conditions identified by the shop that could affect the drivability of the vehicle. These warnings should be provided to the customer both orally and in writing on the customer’s inspection form. Recordkeeping - Body shops should maintain records of all customerrelated correspondence, including repair estimates, warnings, and guaranties or warranties. A repair log should note when repairs were performed, who performed the repairs, a description of the repairs performed, the parts used, and any relevant quality control procedures followed. The length of time that records should be kept will vary depending upon a state’s statutes of limitations. Environmental General - Environmental liability exposures may be controlled through the adoption of good environmental management practices. As a baseline, such practices should include compliance with applicable environmental regulatory requirements. Shops may further reduce their liability exposure through the adoption of pollution prevention practices that reduce the quantity of wastes that must be managed. Regulatory Compliance - Shops should comply with regulatory requirements for hazardous materials and waste management. Federal requirements affect solid and hazardous waste management, used oil management, waste water treatment and discharge, release reporting, Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S refrigerant recycling, and solvent emissions. States may adopt additional or stricter requirements; for example, some states regulate used oil as a hazardous waste instead of a special waste. The EPA and the automotive industry have established a small-business, compliance-assistance center to help automobile body shops comply with environmental regulations affecting the automotive repair industry. The Coordinating Committee for Auto Repair (CCAR) provides information on federal and state requirements, pollution prevention, best management practices and contact information for state and federal officials responsible for regulating the industry. The center may be contacted at 888-476-5465. Material from the center may be accessed online via http://www.ccar-greenlink.org. An annotated, federal regulatory screening checklist for automotive repair facilities is available at www.ccar-greenlink.org/vshops/checklist.html. Work Areas - Floors of vehicle storage and work areas should have sealed concrete or other low permeability surfaces. Berms, curbs, or other spill containment devices should be provided to control large leaks or spills. Outdoor areas should be covered or otherwise protected from stormwater. All floor drains should be identified. Drains located in service bays or wash areas should be connected to a holding tank, a sump, or a municipal sanitary sewer. Drains that discharge to dry wells should be eliminated. Shops should post signs at sinks and paint stencils on floor drains to remind employees not to pour wastes down drains Hydraulic lifts, compressors, parts washers and other fluid containing devices used in the work area should be checked regularly for leaks and potential releases of fluid. Parts washers should be enclosed to prevent fluid loss. Lift systems should be provided with secondary containment. Hazardous Materials - Shops should maintain an inventory of all hazardous materials used by the shop. Materials should be stored according to the recommendations provided by the manufacturer in the Material Safety Data Sheet (MSDS) for the product, as well as the requirements of local building and fire codes. Shops should take steps to minimize the amount of hazardous materials that they have on site at one time. This will reduce the amount of material that may be released should an accident occur and reduce the amount of outdated supplies that must be disposed of as waste. Steps may include redesigning processes to reduce or eliminate the use of the material, maintaining equipment in good working order, training employees in proper equipment use, or adopting strict inventory controls to maximize the use of supplies. Process redesigns can include equipment changes (e.g., using high transfer efficiency paint sprayers), material substitution (e.g., using water-borne primers), or changes in work practices (e.g., or recycling solvents and waster paint thinners). Shops should develop procedures for responding to spills or other emergencies involving hazardous materials. These procedures should be documented in an emergency plan. See the “Housekeeping” section for further discussion on spill cleanup procedures. Housekeeping - Floors should be swept with a broom every day to prevent the unnecessary build up of dirt or other contaminants. Such contaminants can increase the volume or hazard of waste that must be disposed of should a spill occur. Floor washing should be avoided because this practice creates large amounts of wastewater that must be managed. Shops should take steps to prevent leaks and spills. All containers should be tightly sealed when not being used. Approved pumps or spigots should be used to transfer materials from bulk containers. Open pouring of materials should be prohibited. Valves and spigots on dispensing tanks should be checked regularly for leaks. Locking pins or padlocks should be used to prevent the accidental opening of valves. Leaks and spills should be contained and cleaned up quickly. Dry cleanup methods should be used instead of floor washing to reduce the amount of wastewater produced. The type of method used will depend upon the material spilled and applicable regulatory requirements. EPA recommends that absorbent materials (e.g., floor sweep, “kitty litter,” pigs, pads, pillows, or mats) be used to clean up gasoline or solvent spills. [10] This absorbent material should be recycled until it can no longer be used; then properly disposed of. For other materials, EPA recommends using shop rags or towels to wipe up small spills, and mops and buckets, followed by rags, for larger spills. Other methods of dry spill clean up include using brooms, squeegees and dustpans, or wetvacuums to remove the bulk of the spill followed by rags. Recovered 1 1 liquid should be recycled or disposed of as waste and soiled rags rung out, separated, and stored in clearly labeled, closed containers until they can be sent out to be cleaned with other laundry or disposed of. Vehicles should be washed in an area where wash water can be collected, treated, and recycled. State and local authorities should be contacted to determine if treatment is necessary prior to discharge. Wash water should be kept out of storm drains or dry wells. Waste Materials - Shops should perform a waste audit to determine what types of wastes the shop produces, and whether or not this waste is hazardous. The results of the audit can be used as a basis for determining applicable regulatory requirements and waste minimization opportunities. Shops should take steps to recycle commonly generated waste materials, such as refrigerants, solvents, batteries, used oil, and antifreeze. Segregating waste streams can facilitate recycling by reducing the amount of cross contamination. Shops should use a reputable recycling company. Records should be kept of all transactions. Waste materials should be stored safely until they can be recycled or disposed of. All waste materials should be tested to determine whether they are hazardous wastes. Hazardous waste should be kept separate, in properly labeled and sealed containers. The storage area should be protected from rain, snow, and standing water, and should be secured to prevent vandalism. Waste containers should be properly labeled and regularly inspected for signs of leaks or deterioration. Containers must be compatible with the waste stored (e.g., battery acid should not be stored in unlined steel containers). Shops should keep written records of the types of waste stored on the property and the contents of the containers. Waste should be disposed of according to applicable environmental requirements. Hazardous waste should be transported by a licensed hazardous waste hauler and disposed of in a licensed treatment, storage, and disposal facility. Shops should keep waste manifests and other required documentation for at least three years. Pollution Prevention - The number and volume of wastes produced by a shop can be reduced by incorporating pollution prevention practices into shop operations. Such practices may include: (1) decanting solvents to extend solvent life; (2) using paints with low volatility, lower metal concentrations, and higher solid content; (3) calibrating paint transfer equipment; (4) mixing paint only as needed; and (5) using reusable spray booth filters. In addition, shops should take steps to recycle commonly generated waste materials such as refrigerants, solvents, batteries, used oil, and antifreeze. Segregating waste streams can facilitate this by reducing the amount of cross-contamination. Shops should use a reputable recycling company. Records should be kept of all transactions. Property - Crime Exposure Controls A property crime prevention program for an automobile body shop should be designed to reduce the risk of employee dishonesty and fraud, and limit the opportunity for premises burglary. Employee Theft Pre-employment Screening - The first line of defense against employee theft is to hire honest employees at the outset. This is best accomplished through a program of pre-employment screening. By performing in-depth checks of an applicant's job history and references, management can reduce its exposure to theft while creating an environment of honesty. A thorough screening process will convey to employees that management is concerned with ensuring the highest level of integrity in the workforce. Employers should be aware that there are many state and federal laws intended to protect an employee's rights and privacy, and thus impact on an employer's pre-employment screening program. Employers should be familiar with the provisions of these laws and aware of the risks associated with their violation. For additional information, see Liability Report LB70-50, Interviews and Background Checks. Procedural Controls - Service businesses can suffer significant losses from employee collusion with suppliers unless procedures are in place to limit the opportunity. Procedures that make collusion between employees and suppliers more difficult include: arranging work flow and task Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S assignments so that the work of one employee acts as a control on that of another; dividing responsibilities and functions so that no one employee has control over all facets of a transaction; and implementing a program of regular and random (surprise) inventory checks. Expensive tools and equipment should be etched with identification numbers that are recorded, and a list of the numbers and a description of the tool or equipment kept in a secure location. This may help in identifying the item in the event it is recovered by the police. Tools, supplies, and materials should be secured in locked rooms, closets, or chests. Automobile parts and accessories should be kept in a secured room and parts distributed by requisition only. An inventory program should be established as a means of accounting for parts and accessories, as well as tools and supplies. Employee Job Satisfaction - Human resource programs designed to build employee loyalty and align employee and company goals, such as profit sharing, promotion-from-within policies, and fair compensation practices, are effective at reducing employee theft. Through such programs, management can establish an atmosphere of positive attitudes that will benefit the company not only in terms of increased honesty, but in terms of increased productivity as well. Management must enhance employee morale. Enforcement Policy - Although its effectiveness is often debatable, a policy of apprehension and prosecution is considered a control strategy because of its role as a deterrent. The fear of being caught, coupled with dismissal, possible prosecution, and the threat of jail (depending on the severity of the crime), will cause many employees to think twice about stealing. Burglary Building Security - Burglary is a crime of opportunity. Research into the crime indicates that burglars look for places that offer the best opportunity for success. In choosing targets, burglars look for locations that contain something worth stealing and then select those that look easy to break into. Burglars appear to be strongly influenced by the look and feel of the business they are planning to burglarize. Consequently, if the exterior of a business appears to reflect attention to security, the burglar will likely look for an easier opportunity. Good locks and ironwork contribute to making a building appear secure. For additional information, see Crime Prevention Report CP-32-10, Protective Lighting Systems, CP-36-10, Locking Hardware, and CP-37-10, Securing Exterior Doors. Burglar Alarm System - A premises burglar alarm system also may deter a burglar. An UL-Certificated central station burglar alarm system that sends a silent signal to a monitoring station, which dispatches guards on receipt of the signal, is preferred. An alarm system that sounds a local bell is better than no alarm at all - at the very least, it may scare off the burglar. If a safe is used to store cash, or security closet or security cage to store expensive parts or accessories, it should be protected by the alarm system. The alarm system should be tested regularly and maintained properly. A testing and maintenance contract is a requirement of UL Certification. A sign indicating that the premises are protected by a burglar alarm system may serve as a deterrent. For additional information, see Crime Prevention Report CP-48-30, UL Modular Burglar Alarm Certificate Service. Lighting - The exterior of the building should be adequately illuminated, since lighting is believed to serve as a deterrent to burglary. Damaged fixtures and burned-out bulbs should be repaired/replaced on a timely basis. See Crime Prevention Report CP-32-10, Protective Lighting Systems, for additional information. Theft The most effective means for preventing the theft of equipment, tools, and materials, including vehicles, from yard storage areas is to limit access to the site at all times, preferably by a fence with lockable gates. Warning signs should be posted to keep unauthorized persons off the site. All vehicles should be locked and the keys stored in a secure location A secured area should be provided for the storage of equipment, tools, and materials. All tools and equipment should be marked in a conspicuous, distinctive manner to allow for easy identification - this may also serve as a deterrent to theft. 1 2 Fraud Check Fraud - Because of the risk involved, a retail business may have a policy of not accepting checks as payment for goods. For those that accept checks, a check-acceptance policy should be established, the policy should be posted in a convenient location for customers, and clerks should be trained in the policy. Elements of the policy should include: requiring two forms of identification for all payments by check, and listing them on the back of the check; not accepting third-party checks, such as payroll or government checks, since these may be stolen; and using an electronic check verification system. Credit Card Fraud - To prevent credit card fraud, retail businesses should establish a credit card payment policy and train clerks in the policy. Elements of the policy should include: requiring all credit card transactions to be checked electronically; checking the signature on the sales receipt against the signature on the card; and checking the validation and expiration dates on the credit card. Counterfeit Currency Fraud - Retail businesses should train clerks in how to detect counterfeit currency and provide them with equipment that can be used to detect counterfeit currency. The U.S. Secret Service, a division of the U.S. Treasury Department, provides information on detecting counterfeit currency at the following Web site: www.treas.gov/usss/money_detect.shtml. Property - Fire Exposure Controls Facility Design and Construction Building Construction - The facility should comply with local building and fire prevention codes. While codes can vary widely from state to state, some basic measures are common to all codes. These include: fire exposure from adjoining facilities or adjacent structures should be limited by fire barriers or building separation; concealed spaces should be properly fire stopped or otherwise protected; and, in multiple-story buildings, floors should be constructed to act as smoke barriers and vertical openings protected to prevent the spread of smoke and fire. While buildings may be of any construction type, as provided in NFPA 220, Standard on Types of Building Construction, published by the National Fire Protection Association (NFPA), NFPA 101, The Life Safety Code, requires that, regardless of the type of construction, the walls, floors, and ceilings should have a minimum of a one-hour fire resistance rating. Automobile body shops should not be located in the same building as assembly, educational, healthcare, or residential occupancies unless separated by walls, floors, and ceilings having a minimum of a two-hour fire resistance rating, and protected by an automatic sprinkler system. Spray areas, booths, and rooms should be constructed of noncombustible or limited combustible materials having a minimum of a twohour fire resistance rating or be separated from all other areas by a minimum of 3-ft (91.5-cm) clear space. Aluminum should not be used on walls, floors, ceilings, or ductwork where spraying operations are performed. All windows and vision panels for spray booths and rooms should be made form heat treated glass. Paint mixing rooms walls, floors, and ceilings should have a minimum of a one-hour fire resistance rating; a total floor space not exceeding 150 ft2 (14 m2); and should be provided with spill containment. Additionally, mechanical ventilation should be provided with a capacity of 1 cfm/ft2 (0.3 m3/mm2) of floor area, but not less than at least 150 cfm (4m3/min). Means of Egress - Means of egress should be designed in accordance with requirements of NFPA 101 for special hazard industrial occupancies. This means that: a minimum of two fire exits be provided for each smoke compartment; aisles providing access to fire exits not be blocked, that fire exits be provided with panic hardware and not be locked, such as by chains or padlocks, and that doors located in exit paths be equipped with hold open devices, if those devices are designed to automatically close the doors upon activation of the premises fire alarm system. Horizontally sliding fire doors may be used on an exit into a stairwell, when equipped with automatic closure devices that are activated by a smoke detection system. When one or more smoke detectors activate, all doors leading to the stairwell should close. These doors should also be Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S provided with a manually operated, instantaneous release device for occupant use. Horizontally sliding fire doors should have a fire resistance rating of at least one hour and four hours for building greater than three stories in height. The locations of fire exits should be indicated by clearly visible signs. Walkways around machinery should be a minimum of 22 in (56 cm) wide. The maximum travel distance to fire exits should not exceed 50 ft (15 m) from any location in the facility. This distance may be extended to 100 ft (30 m) if the facility is protected by an automatic sprinkler system. Utilities Electrical - The electrical system should comply with NFPA 70, National Electrical Code. Some basic requirements of NFPA 70 include: electrical conductors should be securely fastened in place; outlet and junction boxes should be properly secured, covered, and without evidence of overheating; wiring insulation in outlet and junction boxes should be in good condition and not frayed or loose; an adequate number of electrical outlets/circuits should be provided to avoid overloading of circuits; the use of extension cords should be prohibited; electrical panels and branch circuit disconnects should be freely accessible at all times; and all electrical equipment should be inspected and maintained according to manufacturer’s instructions. Electrical equipment used in wet areas, such as wash areas and restrooms, should be equipped with ground fault protection. The electrical systems in areas where paints and solvents are stored, mixed, or dispensed should be approved for Class I, Division 2 locations, in accordance with NFPA 70. In addition, electrical equipment located within 20 ft (6 m) horizontally and 10 ft (3 m) vertically of unenclosed spray areas; or within 3 ft (91 cm) of enclosed spray booths; and inside all spray booths, rooms, and hoods; should be approved for Class 1, Division 2 use. Heating and Air Conditioning - Heating and air conditioning systems should comply with NFPA 90B, Standard for the Installation of Warm Air Heating and Air Conditioning. Air circulation systems should be designed to automatically shutdown in the event of a fire. Proper maintenance of these systems will help to prevent overheating of motors, which could result in fires. Other factors to be considered include: (1) Heating systems should be located in a separate area with a minimum of fire resistance rating of one-hour and having no opening with in 8 ft (2.4 m) of a hazardous area such as paint spray areas; (2) return air for heating systems should be at least 18 in (45.5 cm) above the floor; and (3) solid fuel and portable heating units should be prohibited. Storage Areas Supply Rooms - Supplies should be stored in conformance to local fire code requirements and follow good storage practices. The specific types of storage practices will depend upon the products and storage arrangements, as follows: (1) supplies should be stored on stable surfaces, in stable configurations, and stock should not block access to fire and emergency exits; (2) adequate aisles/spacing should be provided to limit congestion, prevent the spread of fire, and provide for fire fighting access; (3) ordinary combustible materials, such as records, tools and paper supplies, should be stored separate from flammables liquids; and (4) storage rooms, trash rooms, and similar areas should be separated from other areas by one-hour fire barriers or protected by automatic sprinklers. Flammable and Combustible Liquids Storage - Automobile body shops may store a variety of flammable and combustible liquids, such as degreasers, paint, solvent, and lubricants. Flammable and combustible liquids should be kept in covered containers when not in use. Spills should be cleaned up promptly. Flammable and combustible liquids should be stored in accordance with NFPA 30, Flammable and Combustible Liquids Code. Storage rooms containing flammable or combustible liquids should be segregated by fire barriers or separated from the facility and protected by and automatic sprinkler systems. Inside storage should be limited so that not more than 120 gal (454 l) of flammable or combustible liquids are stored in any one cabinet, and no more than three cabinets should be located in the same storage area. In addition, storage areas should be provided with spill-containment devices; electrical equipment that is approved/listed for a Class 1, Division 1 use; and equipped with ventilation equipment designed to maintain a constant flow of air to prevent the buildup of flammable vapors. 1 3 See Fire Protection Report FP-70-12, Storage of Flammable and Combustible Liquids in Containers, for additional information on this topic. Fire Suppression and Alarm Systems Fire Alarm System - A fire alarm system should be designed, installed, and maintained in accordance with requirements of NFPA 72, National Fire Alarm Code. The system should be monitored by a central station alarm company, with automatic retransmission of fire alarm signals to the fire department. NFPA 72 requires that a fire alarm system be covered by a maintenance and service contract, and regularly tested and inspected. The system should include both manual and automatic initiation devices that provide immediate evacuation notification to the occupants. Activation of the system should cause the release of hold-open devices on smoke compartment doors. Fire Suppression Systems - The building(s) should be protected by an automatic fire sprinkler system meeting the requirements of NFPA 13, Standard for the Installation of Sprinkler Systems. Requirements for maintaining sprinkler systems are contained in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-based Fire Protection Systems. Sprinkler systems in paint spray areas should meet the requirements for Extra Hazard Group I, in accordance with NFPA 13. In addition, separate sprinkler control valves should be used to supply sprinkler protecting paint spray areas. Sprinkler heads located in paint spray areas should be protected from over-spray by thin paper bags or cellophane, not exceeding 0.003 in (0.072 mm) thick. When service, repair, or maintenance activities will impede the sprinkler system for more than four hours (in a 24 hour period), the fire department should be notified. In addition, the building should be evacuated or fire watch established during the period of system impairment. Fire extinguishers should be located throughout the facility, in compliance with local codes and as required by NFPA 10, Standard for Portable Fire Extinguishers. Employees should be trained in the care and use of these extinguishers, including proper selection and application for the classes of fire presented. Properties located in areas without public water systems should be protected by alternate water sources, in accordance with NFPA 1142, Standard on Water Supplies for Suburban and Rural Fire Fighting. Operations Smoking - Smoking should be prohibited. If smoking is permitted, designated smoking areas should be established and “No Smoking” signs should be posted in all other areas of the facility. Improperly discarded smoking materials, such as cigarettes, can ignite combustible waste. Noncombustible receptacles for smoking materials should be provide and routinely emptied by the staff. Housekeeping - Used cardboard cartons, packing, and crating materials can accumulate in stock rooms, increasing the fire load in such areas. To minimize the danger of fire, stock rooms should be tidy and orderly, and trash should be removed to an outside trash dumpster or otherwise disposed of. Storage rooms, trash rooms, inside dumpsters, and similar areas should be separated from other areas by one-hour fire barriers or protected by automatic sprinklers. Equipment Cleaning - Equipment cleaning operations using flammable or combustible liquids should be conducted in well-ventilated areas, away from open flames and other ignition sources. Liquid-soaked rags and paper from cleaning operations should be placed in covered metal containers and disposed of on a daily basis. Paint Mixing - Paint should be mixed only in rooms designed for such operations or in the area where the paint will be immediately used. Smoking should be prohibited in areas where paint is mixed. Solvents and thinners with a flashpoint below 100oF (37.8oC) should not be transferred between containers unless both containers are bonded and grounded. Proper bonding/grounding is required to prevent the buildup of static electricity produced by the transfer of liquids. Provisions for bonding and grounding include: connecting the containers to each other electrically, before transferring the liquid; and connecting both containers electrically to earth ground, before transferring the liquid. See Fire Protection Report FP-70-08, Static Electricity, for additional information on this topic. Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S Repair Areas - Body repair and alignment operations should be performed in areas designated for such work and separated from painting operations by a minimum of a one-hour fire rated wall. Typical control measures that should be implemented for repair areas include: (1) the electrical service should be of sufficient capacity to handle the heavy loads created by the many types of electrical equipment used in repair shops; (2) all electrical equipment should be properly grounded to prevent the generation of sparks; (3) cutting, welding, and soldering operations should use a hot work permitting system; and (4) dust collection systems should be provided in areas where metal and body fillers are sanded. Paint Spraying - Fire prevention controls for paint spraying operations will vary based on the type of material sprayed, the rate of application, and the area where painting is performed. Painting operations using flammable and combustible liquids present the greatest risk for fire and should comply with NFPA 33, Spray Applications Using Flammable and Combustible Liquids. Walls and ceilings surrounding spray booths or rooms should be constructed of and separated from surrounding areas by firewalls or fire barriers. Electrical wiring and equipment, such as electrostatic spray application equipment and drying, curing and fusing apparatus, should be in accordance with NFPA 70. Light fixtures in spray booths and rooms should be listed or approved for the application. Ventilating and exhaust systems should be designed and installed in accordance with NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids. Spray should be equipped with a ventilation system that is capable of confining and removing vapors and mists to a safe location. Paint spray ventilation systems should be designed and monitored to ensure that flammable vapor concentrations do not exceed 25-percent of the lower explosive limit (LEL). In addition, exhaust ducts should be: (1) ported to the outside, away from air intakes, and at least 6 ft (18 m) from exterior walls and roofs; (2) directed away from any combustible exposures; and (3) not be used as part of the general building ventilation systems. Spray operations should be confined to pre-determined areas designed and maintained for spray operations. The use of chlorinated solvents in paint spraying areas and equipment should be prohibited. All spray areas should be kept free of the accumulation of deposits of combustible residues. Filters for ventilating and exhaust systems should be replaced on a regular basis. See Fire Protection Report FP-70-10, Paint Spray Processes, for additional information on this topic. Drying and Curing - Drying, curing, and fusing equipment used in connection with the spray application of flammable and combustible paints and materials should meet the requirements of NFPA 86, Standard for Ovens and Furnaces. Heating systems for paint drying should be interlocked with the spraying equipment so that no spray operations can be performed while the heating system is active. Further, the heating system should be designed to shutdown if the drying area temperature exceeds 200oF (93.3oC). Emergency Preparedness In order to ensure that customers and employees are prepared to evacuate the facility, the following practices should be followed: (1) employees should check the exit doors and exit paths on a daily basis to ensure access during an emergency; (2) emergency evacuation drills should be conducted on a semi-annual basis; (3) during evacuation drills, all of the alarm components should be activated; (4) personnel should be assigned to assist with the orderly evacuation of the occupants; and (5) all employees should be trained in the proper selection and use of portable fire extinguishers. See Fire Protection Report FP-45-10, Emergency Action Plans (OSHA 1910.38), and FP-45-15, Fire Prevention Plans, for additional information on this topic. Incendiarism and Arson Basic protection against incendiarism and arson requires that the property be secured from unauthorized entry and equipment protected. A fence should protect the perimeter of the property. All exterior areas of the property should be illuminated. Trees and vegetation should be cut back to provide a clear space of at least 100-ft (30.4-m) clearance around the perimeter of the property. Combustible materials and trash in yard areas should be properly discarded. Deadbolt locks should be 1 4 installed on all exterior doors. Ground level and below-grade windows, and other accessible openings, should be secured. Yard storage and vehicles should be kept away from the building so as not to present an exposure to the building and its contents. Yard storage should not be located too close to perimeter fencing since arsonists may be tempted to burn yard storage or vehicles if they can't get to the building itself. A distance of 25 feet between yard storage and fences or buildings is recommended. Yard storage also should be arranged with adequate aisle space. See Fire Protection Report FP-42-01, Incendiarism and Arson, and Crime Prevention Report CP-30-10, Physical Protection Afforded by Buildings, for additional information on these topics. Property - Inland Marine Exposure Controls Inland marine loss control management for an automobile body shop is that portion of a complete management system that deals with preventing loss of income due to damage or loss of automotive body shop equipment, accounts receivables, valuable papers and records, electronic data processing equipment and media, property in transit, and signs and awnings. The loss control management program should also address garage keeper’s liability and the potential for business interruption. An inland marine loss control program should be incorporated into the automobile body shop’s operating procedures. Equipment Inventory -The types of equipment that are exposed to loss include: paint guns, blow guns, spraying equipment, hoses, mixing bank, paint gun cleaning machines, paint testing equipment, paint thinner recycling machine, color mixing software machine, sanding and grinding equipment, respirator equipment, air compressors, hand tools, electric or air-powered hand tools, jacks, lifts, materials and handling equipment, chain hoists, wheel alignment and hydraulic machines, pneumatic metal cutting guns, stud guns, welders, computerized measuring and replacement parts systems, air-conditioning equipment, washers and dryers, cleaning/maintenance equipment, special furnishings, general office equipment, audiovisual equipment, televisions, VCRs, radios, photocopiers, vending machines, coffee makers, security monitoring cameras, and public address systems. Additionally, auto body technicians generally are expected to provide their own tools. A complete set of tools owned by a master technician could be quite costly and, as such, consideration should be given to their safekeeping. A list of the ages, condition, and serial numbers for all equipment leased or rented should be maintained in a secure location, preferably offpremises in a fire resistive safe. Security - All equipment should be secured against vandalism and theft. Expensive equipment should be protected from theft by etching with identification numbers. A list of the numbers and descriptions of the equipment should be registered with the police and copies of the list kept in a secure location. All high-value, specialty equipment should be placed in a secure location when not in use. An accurate inventory and videotapes and/or photographs of all specialized equipment should be kept. Portable equipment, when not in use, should be kept in a locked storage room or cabinet. For additional information, see Property - Crime Exposure Controls section of this report Garage Keepers’ Legal Liability Loss Prevention - Both the owner and the customer have a financial interest in a vehicle left in the care, custody, and control of the shop. The vehicle remains on a temporary basis at the shop and then returned to the customer. The shop is required to exert the same degree of care that an ordinary, careful person would exercise over his or her own property. Certain repairs (e.g. airbags, stereo, and engine repairs) may be subcontracted out to qualified specialists. Customers’ vehicles in the care and custody of the shop should be secured against loss, vandalism, and theft, and protected against fire, water, or nonfortuitous damage. A protection program for these types of properties should include: visually inspecting vehicles for valuable items; Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S reminding customers to remove any valuable items from vehicles left for repair; posting signs that the shop is not responsible for any items left inside the vehicle; establishing a key-control program to prevent unauthorized access to vehicle keys; and storing vehicles in secure areas away from fire hazards and taking steps to protect vehicles from expected adverse weather conditions. Subcontractors - If work is performed by outside subcontractors, their qualifications should be checked. In addition, they should be required to sign an Indemnification and Hold Harmless Agreement. For additional information on liability, see Liability – Exposure Controls section of this report. Accounts Receivables Records Protection - A business that suffers a loss due to fire, flood, or other natural disaster may be unable to collect accounts receivables and/or other monies owed. Valuable papers and records, such as customer’s names and address, payment and credit accounts, inventory records, receipt record books, contractual agreements, rental agreements, insurance documents, inspection and audit records, deeds, and mortgages, may also be damaged or destroyed. Plans should be developed to protect accounts receivables. Records should be duplicated and updated on a regular basis, with off-site storage of backup records. Otherwise, accounts receivable records should be stored in the appropriate record protection equipment that is used only for such purpose. Contingency plans should be in place to retrieve and recover damaged records. Fire Protection - Automatic sprinklers, smoke detectors, or other fire protection systems that are intended to protect the facility also will serve to protect accounts receivables. Smoking should be prohibited throughout the facility or restricted to specifically designated areas. Valuable Papers/Records Records Protection - Many types of papers or records have a value beyond their physical worth. Valuable papers and records can be documents that are needed to operate the facility or items of historical value. They are records that are usually written, and can include customers’ and parts’ suppliers names and addresses, credit accounts, books, auto body manuals, paint charts, drawings, technical data sheets for body repair, contractual agreements, leasing agreements, repair warranties, insurance documents, inspection and audit records, documentation of body shop stock and values, deeds, and mortgages. Money or securities are not included as valuable papers. Valuable papers and records should be stored in a fire-resistive cabinet or safe and backup copies stored off premises. Automatic sprinklers, smoke detectors, or other fire protection systems that are intended to protect the facility also will serve to protect valuable papers/records. Smoking for both employees and customers should be restricted to designated areas. Business Interruption Emergency Planning - Business interruption insurance would protect against both a direct loss of income resulting from a fire or other natural disasters temporarily closing the automobile body shop, and also the extra expenses incurred for fixed costs and retaining key employees. The location of the business will be vital to its continued operation. These businesses depend on repeat customers who live within a 30-mile radius. A lengthy business interruption could have a long-lasting impact on the future of the business. An emergency preparedness plan should be in place to respond to emergencies, such as fires or natural disasters. The plan should be designed to limit potential damage so as to keep the business operating or, in the event of a closing, to bring it back to operation as soon as possible. Records of natural disasters in the area should be obtained and analyzed. This analysis could help to determine the emergencies that should be considered in the plan. For additional information on emergency planning, see Natural Hazards Reports NH-30-10, Emergency Response – An Overview; NH-30-11, Emergency Response – Developing the Plan, NH-30-12, Emergency Response – Example Plan; NH-30-14, Emergency Response – Recovery Operations; and NH-30-15, Emergency Response – Protecting Vital Records. Fire Protection - To limit business interruption losses from fire, the facility should be designed and constructed to minimize the potential for fire and, in case of a fire, to contain the fire to the area of origin. Requirements for fire protection are provided in the Property - Fire Exposure Controls section of this report. 1 5 Electronic Data Processing Equipment and Media Records Protection - EDP equipment and media include computer hardware and software, specialized software, computer data, and storage media, including discs and magnetic tapes. Telephone systems and fax and copy machines can also be included. Most body shops will keep detailed customer files on a computerized database for their records. Some body shops may use specialized computer software and equipment to estimate repair costs, and order replacement parts. The exposure to loss for electronic data processing and computer media equipment can include: fire, flood, smoke, extreme heat or other natural disasters; computer fraud, errors and omissions; power outages and brownouts; lightninginduced electrical surges (e.g. spikes of electricity); and burglary and theft. EDP equipment and media should not be located in basement locations to limit damage from floods, and should be provided with surge protection to protect against lightning-induced electrical surges. Backup copies of specialized software should be stored in the appropriate record protection equipment, or at an off-premises location. Backup copies of critical data, such as medical and financial records, should be kept in offsite storage facilities. Computer files should be backed up daily. Fire Protection - An automatic sprinkler system can help to minimize losses from a fire. For more information on fire protection, see the Property – Fire Exposure Controls section of this report. Inventory - An inventory system should be established for all EDP equipment and media. This will help to determine if theft is a problem and whether or not security measures are affective. Property in Transit If the business is part of larger operation, or a franchise operation, transportation of property between locations may be required. The mode of transportation can be by flatbed or tow trucks or by commercial vehicles. The property can be damaged in an accident or subject to theft or hijacking. A loss control evaluation of all aspects of the transportation cycle should be considered. All equipment should be secured during transportation. Up to date, information should be kept on the average and maximum value of all materials and equipment transported or stored in vehicles. If equipment and materials are stored in vehicles, the vehicles should be protected with alarms and locks. Signs and Awnings Outdoor signs and awnings can be exposed to loss. Generally, outdoor signs less than 12 feet (3.65 meters) above the sidewalk are not covered under an inland marine policy. The types of signs exposed to losses include neon, florescent, automatic or mechanical electrical signs, and lamps. Signs can be of the freestanding type or on a raised pole. Additional signs may be attached to the main building or to the roofing. Signs and awnings should be designed to withstand expected weather conditions and properly supported to prevent toppling. Signs should be located with adequate setbacks from parking areas or roadways. In locations where there is a potential for a sign being struck by vehicles, it should be elevated or protected by safety barriers. Properly illuminating signs will help to deter theft or vandalism. An inventory of all signs and awnings should be maintained. Workers’ Compensation Exposure Controls Management System Establish Safe-Work Procedures - Management and workers should be aware that the cost of accidents has a direct influence on the cost of operating the business. Management can take many actions that will directly impact the level of safety and subsequent accidents. First is a positive, no-nonsense demand that workers use established safe-work procedures. Management must insist on strict adherence to safety protocols and the use of approved personal protective equipment (PPE). Management also should lead by example and perform all tasks in a safe manner. Written Safety Program - The organization should have a written safety program to help stress the seriousness of working safely and to help Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S identify all the exposures that need to be addressed. Outlining the expected safe work procedures will aid in on-the-job training and set a foundation for unsupervised work. Management should provide initial and continuous safety training. Employee Training - All workers should have a clear understanding of management’s attitude toward safety. They should have and use the proper safety equipment and PPE for the task at hand. Workers should be responsible for inspecting their PPE each day. Workers who have a voice in the selection of PPE will generally be more receptive to its use. Workers should not take shortcuts or guess at the proper method to accomplish the task. Instead, workers should know they can count on management to help them when difficult situations arise, and that they will be rewarded for safe acts. General Hazards General Requirements - Procedures should be established to ensure workers are trained on the safe use and operation of machinery/equipment. Workers also should be trained on the safe use of hydraulic vehicle lifts and jacks. In addition, procedures should be established to ensure inspections and preventative maintenance is performed on all machinery and equipment. PPE, such as safety shoes, gloves, and safety glasses and goggles, should be provided and used when operating equipment, such as bench grinders, right angle grinders, welders, and other hazardous tools/equipment. Workers should be advised not to wear loose-fitting clothing or jewelry when operating equipment and machinery. Workers with long hair should be advised to tie it back. Lockout/tagout procedures should be established to prevent the unintended startup of machinery/equipment during service and maintenance operations. Fan blades 7 feet (2.1336 m) or less from the floor should be guarded in such a manner that no openings greater than ½ in (12.70 mm) exist. Fixed machinery should be securely anchored to prevent movement. Signs should be posted on storage lofts and second floors indicating floor-load capacity. Hoists or cranes should be operated within their rated load capacity and provided with hook safety latches. Glass Safety - Workers should wear appropriate eye and skin protection when handling glass. The edges of glass should be inspected for slivers and rough or sharp edges before handling. Workers should not carry glass under the arms or over the head. Glass should be held with palms outward so that it can only fall away from workers in case of an accident. Workers should be instructed to stay on the side with vacuum cups when carrying glass. Vacuum cups should be kept clean and dry to ensure proper gripping of the glass. Battery Safety - Appropriate PPE, such as eye and face protection, aprons, and gloves, should be worn when handling batteries. Workers should be instructed not to smoke or have open flames or sparks near a battery. When removing or installing a battery, workers should: (1) follow the vehicle maker’s recommendations; (2) shut off all electrical loads before disconnecting or reconnecting the terminals; (3) disconnect and isolate the negative (ground) cable first, and reconnect the negative cable last. Workers should ensure the charger is turned off before connecting or disconnecting it to a battery. The markings on the battery, not the position of the cables, should be used to determine the polarity of the terminals. Grinders - Bench and pedestal grinders should be provided with safety guards to cover the spindle, nut, and flange projection. Adjustable tongue guards on the top side of the grinder should be adjusted to within ¼ inch (6.3500 mm) of the wheel, and work rests adjusted to within 1/8 inch (3.1750 mm) of the wheel. Portable right angle grinders should be provided with a safety guard. Electrical - Grounding should be provided for all fixed equipment and grounded conductors should be provided for all cord- and plugconnected equipment. Hand and portable power tools should be provided with grounding or be double insulated, and extension cords should be provided with grounding lugs and free from splices. For additional information, see Occupational Safety Report OS-30-10, Electrical Safety. Jacks - Jacked motor vehicles should be provided with cribbing, blocked, or otherwise secured. Support stands should be provided after the vehicle has been raised with a hydraulic jack. 1 6 Hand and Power Tools - Chisels, punches, and similar tools should be maintained in safe operating condition without worn or mushroomed heads. Wrenches should be maintained without worn or bent parts, and hammers should be without broken or cracked handles. Pneumatic tools should be checked to ensure they are securely fastened to the air hose to prevent them from becoming disconnected. A short wire or positive locking device attaching the air hose to the tool should be used as an added safeguard. For additional information, see Occupational Safety Report OS-55-28, Hand and Power Tools Safety. Compressed Air Equipment - Compressed air used for cleaning should be reduced to 30 psi (207 kPa) when dead-ended. Safety-relief valve(s) should be provided on the air compressor tanks and tested at regular intervals to assure safe operating condition. The air tank drain valve should be opened frequently to prevent excessive accumulation of liquid and the pressure controller and gauge should be maintained in good operating condition. Flexible cords or plugs on electric motor-driven compressors should be periodically checked and replaced, if deteriorated. Employees should be instructed to not use compressed air to blow dirt from clothing or the body because it can enter the body through cuts or openings and cause serious harm. Service Bays - Service bays should be constructed of masonry, concrete, or other noncombustible material and should be provided with a minimum of two unobstructed means of egress to prevent trapping of workers in case of an emergency. Housekeeping, such as storing materials on shelves rather than in the aisle, should be maintained to ensure a safe working environment. Emergency equipment, such as a fire extinguisher, should be provided in the vicinity of the service bay. Surface-Mounted and In-Ground Vehicle Lifts - Hoist controls should be manually operated and not blocked into the open or shut position. Only authorized and trained employees should be allowed to operate lifts. Workers should be instructed to stand to one side of vehicles when directing them into position over the lift. Vehicles should be prohibited from being raised with passengers inside. Vehicle doors and hoods should be closed before raising the vehicle. If a lift is equipped with a mechanical locking device, it should be engaged when the lift is up. When a lift malfunctions, it should be removed from service until repaired. Malfunctioning can include: it jerks or jumps when raised; it slowly settles down after being raised; it slowly raises when not in use; it rises slowly when in use; it comes down very slowly; it blows oil out of the exhaust line; or it leaks oil at the packing gland. Tire Changing Equipment - A safety tire rack, cage, or equivalent protection should be provided and used when inflating, mounting, or dismounting tires installed on split rims, or rims equipped with locating rims or similar devices. Tire cages should be provided and used when repairing truck tires. OSHA Standard 29.CFR 1910.177 Servicing Multi-Piece and Single Piece Rim Wheels, provides safety requirements for the servicing of multi-piece and single piece rim wheels used on large vehicles, such as trucks, tractors, trailers, buses, and off-road machines. Compressed Gas Welding - Compressed gas cylinders should be stored away from radiators and other sources of heat. They should be stored inside buildings, in a well-protected, well-ventilated, dry location that is at least 20 feet (6.0960 m) from combustible materials, and located away from elevators, stairs, and gangways. They should not be kept in unventilated enclosures, such as lockers or cupboards. Cylinder caps should be in place when cylinders are not in use. Stored oxygen cylinders should be separated from stored fuel gas cylinders or combustible materials (especially oil or grease) by a minimum distance of 20 feet (6.0960 m) or by a noncombustible barrier at least 5 feet (1.5240 m) high and having a one-half hour fire-resistance rating. All cylinder valves should be closed when work is finished. Where a special wrench is required, it should be left in position on the stem of the valve while the cylinder is in use so that the fuel-gas flow can be quickly turned off in case of emergency. In the case of manifold or coupled cylinders, at least one such wrench should always be available for immediate use. All cylinders should be legibly marked to indicate contents. Cylinders should not be permitted to stand alone without being secured with lashing or chain to prevent toppling over. Acetylene should not be used at a pressure in excess of 15 psi gauge (103 kPa), or 30 psi absolute (207 kPa). Indoor storage of compressed gas should be limited to a total capacity of Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S 2,000 cubic feet (56.6335 m3) or 300 pounds (136.0800 kg) of liquefied petroleum gas. Hoses should be maintained without leaks, burns, or worn sections. All resistance welding equipment should be periodically inspected by competent personnel. Cutting and welding should not be permitted in the presence of explosive atmospheres that may develop inside unclean or improperly prepared tanks or equipment. Individual booths or non-combustible screens should be provided to enclose the welder. Proper eye protection should be provided for welders and adjacent workers, and respirators should be required to be worn when welding or cutting in confined spaces. Appropriate fire protection equipment should be readily available. Electrical Arc Welding - Employees should be instructed on the safe use and operation of electrical arc welding equipment. If the welding machine gets wet, it should be thoroughly dried and tested before use. The atmosphere in the welding areas should be free of flammable gases, liquids, and vapors. Coiled welding cable should be spread out and the ground lead should be firmly attached to the work. Cables should be inspected for damage and loss of insulation and repaired before use. Ground and electrode cables should be joined together only with connectors specifically designed for that purpose. Cables with splices within 10 feet (3.0480 m) of the operator should not be used. Workers should be instructed not to coil cables around their body. Welding helmets or hand shields should be worn by the operator. Persons close by should be required to wear eye protection. Shields, such as fire-resistant curtains, should be used to protect nearby personnel. Arc-welders should be required to wear clean, fire-resistant gloves; clothing with collars, and sleeves should be buttoned. Proper eye protection should be provided for welders and adjacent workers for flash protection. Hot material should be marked with soapstone or in some other way. Electrode holders not in use should be put in a safe place (for example, away from conducting objects). Appropriate fire protection equipment should be readily available. Carbon Monoxide - Air monitoring should be performed to assure carbon monoxide emissions from automotive exhaust and space heaters do not exceed the OSHA permissible exposure limit (PEL) of 50 parts per million (ppm) for an 8-hour time-weighted average (TWA). If the OSHA PEL is exceeded, engineering controls (e.g., exhaust ventilation), administrative controls (e.g., job rotation, medical monitoring, etc.), and/or the use of PPE (e.g., respirators) should be implemented. Vehicle exhaust fumes should be vented to the outside of the body shop. Noise - Noise monitoring should be conducted to assure noise levels throughout the shop from use of pneumatic tools, hammers, grinders, etc., do not exceed the OSHA PEL of 85 decibels for an 8-hour TWA. If the OSHA PEL is exceeded, an OSHA Hearing Conservation Program (e.g., annual audiometric testing, employee training, use of hearing protection devices, etc.) should be established. Additionally, if the noise PEL’S in Table G-16 of OSHA Standard 1910.95 Occupational Noise Exposure is exceeded, feasible engineering or administrative controls should be implemented. Dry and Wet Sanding - Workers are exposed to the inhalation of airborne dusts, some of which contain toxic chemicals, when performing dry sanding. To minimize dust exposure, workers should be provided with and required to use vacuum sanders, downdraft or cross-draft prep stations, and/or appropriate respirators. Because painters usually perform wet sanding after spraying primer on a vehicle part, wash water from wet sanding may contain trace amounts of organic chemicals from the primers. Chemicals-resistant gloves and aprons should be worn during wet sanding to minimize dermatitis. Solvent Wiping - Workers are exposed to both skin absorption and inhalation of hazardous and toxic chemicals when performing solvent wiping. To minimize these exposures, workers should be provided with and required to use safety solvents (or less hazardous and toxic solvents), proper gloves, downdraft or cross-draft prep stations, and/or appropriate respirators. Mixing Paints - Workers are exposed to both skin absorption and inhalation of hazardous and toxic chemicals when performing paint mixing. To minimize these exposures, workers should be provided with and required to use chemical-resistant gloves and paint suits. Local and general exhaust ventilation, and appropriate respirators, should be provided. Painters should be required to use non-hazardous cleaning 1 7 agents to remove paints from their hands and arms, rather than solvents. In addition, inhalation of solvent vapors can be minimized by requiring workers to close all containers of painting materials immediately after their use. Paint Spraying - Workers are exposed to both skin absorption and inhalation of hazardous and toxic chemicals when performing paint spraying. High-volume, low-pressure (HVLP) spray guns should be provided and used to spray primers, basecoats, and clear-coats. HVLP spray guns are recommended since they have notably higher transfer efficiency than conventional spray guns. This means that more paint is placed on the vehicle rather than in the work environment, resulting in reduced exposure to the worker. The transfer efficiency of HVLP guns, and therefore the amounts of paint overspray generated, are highly dependent on the gun settings that a painter selects (e.g., pressure in the air feed line) and on the painter’s spraying technique. Paint spray operators should be trained on the paint distributors and gun manufacturers operating procedures to improve the transfer efficiencies when using HVLP guns. Paint spraying operations should be performed, when possible, in wellventilated spray booths. The continued effectiveness of spray booth ventilation should be ensured through regular filter changes, cleaning, and additional preventative maintenance. Some quantities of paint overspray may linger in spray booths after spraying has been completed. To ensure the removal all overspray from spray booths the ventilation system should be run for several minutes after spraying has been completed. The National Institute for Occupational Safety and Health (NIOSH) recommends that painters use supplied-air respirators during all spraying operations, even those performed in downdraft spray booths. Supplied-air systems typically provide far superior respiratory protection to workers than air-purifying respirators. These systems also eliminate concerns regarding cartridge change-out procedures and, depending on the type of facemask used, concerns that workers may not achieve face to face piece seals. Workers should be provided with, and required to use, chemical resistant gloves, paint suits, and head socks while spraying vehicles. Spray Gun Cleaning -Workers are exposed to both skin absorption and inhalation of hazardous and toxic chemicals when performing spray gun cleaning. To minimize these exposures, workers should be required to perform gun cleaning tasks in a well-ventilated area. Workers should be provided with, and required to use, safety solvents or less hazardous and toxic solvents. In addition, chemical resistant gloves, paint suits, and appropriate respirators should be provided and used. Strain Prevention Prevention Program - Management should have a strain prevention program that outlines the procedures for the safe use of equipment, provides criteria for two-person lifts, and reinforces the need for storing heavy objects at waist level. Employee Training - Much of the success in preventing strain injuries can be attributed to understanding the exposure. Workers can help to prevent a back injury or strain by reducing bending and twisting, and getting help with heavy loads. Manual materials handling equipment should be sized for the task and the user. Additionally, management should know which workers have back problems and ensure they are lifting safely, such as by using a buddy system. Finally, the best prevention technique to control strain injuries is recognition by the individual of the hazard and then taking the appropriate action. There should be no stigma attached with asking for help. Hazardous Substances Personal Protection Equipment - Occupational injuries and illnesses can be caused by exposure to harmful substances or the environment. Management should conduct a hazard assessment to determine what PPE should be worn. PPE, such as hard hats, safety shoes, gloves, boots, aprons, face shields, goggles, hearing protection, respirators, etc., may be necessary to prevent worker injury. In addition, workers should be trained on the proper selection, use, and maintenance of PPE. For additional information, see Occupational Safety Report OS-70-02, Personal Protective Equipment, and Report OS-70-11, Occupational Eye and Face Protection. OSHA Hazard Communication Program - A formal Occupational Safety and Health Administration (OSHA) Hazard Communication Program should be established to control the handling of hazardous chemicals used by workers in garden centers. The program should include Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S written procedures, hazardous materials inventory, MSDSs, worker training, and container labeling. For additional information, see Occupational Safety Report OS-20-12, Hazard Communication. Other Factors - Other factors that should be considered for protecting workers from hazardous chemicals include: (1) provide spill clean-up kits in accessible locations; (2) develop and implement written spill control plans; (3) store chemicals in areas that are not subject to physical damage; (4) do not store heavy loads on top of small, chemical-holding containers; and (5) provide proper PPE for each chemical used. Fall Prevention Climbing - Workers need to be vigilant when climbing and descending stairs, and while using ladders or step stools, to ensure they are free from slippery conditions. Walking Surface - When pulling or pushing carts or lifting equipment, workers should analyze the path to the destination and take appropriate actions. Conditions that could cause a fall should be corrected or bypassed. Management should consider the following to reduce worker exposure to falls: (1) require workers to wear shoes with a slip-resistant sole; (2) have workers clean up liquid spills as quickly as possible; (3) coat building steps with a non-slip material; (4) keep walkways and parking areas clear and unobstructed from debris, snow and ice; (5) provide adequate lighting indoors and outdoors, including on walkways and in parking areas; and (6) inspect and properly maintain all portable ladders and step-stools. A standard safety railing should be provided for all open-sided floors or platforms (e.g., storage lofts, balconies, etc.) 4 feet (1.2192 m) or more above the adjacent floor or ground level. A toeboard also should be provided with the safety railing wherever people walk beneath. Permanent aisles should be appropriately marked to indicate access areas Cooking Operations Written Procedures – There are numerous methods to protect workers in a cooking environment. Since these methods may differ by operation, management should ensure the procedures they want followed are clearly spelled out. Some of the preventive methods that may be used include: (1) posting caution signs on hot counter surfaces below heat lamps; (2) providing towels, dry cloths, mitts, or potholders to handle hot utensils and appliances; (3) cleaning stoves and hoods on a regular basis to prevent grease buildup; (4) keeping oven doors closed when not being used; and (5) cleaning ovens, stoves, and other hot cooking equipment only after they have cooled Powered Industrial Trucks Fumes - Carbon monoxide fumes emitted by powered industrial trucks should be monitored and controlled; battery-powered industrial trucks should be used whenever possible. If this is not feasible, propane- or diesel-powered industrial trucks should be properly tuned-up or catalytic converters added to reduce carbon monoxide emissions from internal combustion engines. In addition, in closed environments, carbon monoxide alarms should be installed and air quality testing should be provided on a routine basis. Forklift operators exposed to diesel exhaust in the work environment may also be at risk for health problems. The composition of diesel exhaust varies depending on engine type, operating conditions, lubricating oil, and whether an emissions control system is present. Diesel exhaust can cause eye irritation and respiratory problems, and has the potential to cause cancer. There is no OSHA standard for diesel exhaust. Employee Training - Only trained and authorized workers should be allowed to operate powered industrial trucks, as required by the revised OSHA Powered Industrial Truck Standard 29 CFR 1910.178. Training should include classroom lecture, visual aids, and hands-on driving skills evaluation, equipment-specific training, and documented with certificates of completion. Back-Up Controls - Back-up alarms should be installed on powered industrial trucks to help prevent struck-by or caught-between injuries. In noisy locations, flashing lights should be installed in place of alarms. Trucks should be equipped with convex or panoramic rear-view mirrors to provide operators the best view possible. Operator Protection - Forklift trucks should be provided with an overhead guard to protect the operator from falling materials. They 1 8 should also be provided with a load backrest extension to support the load being lifted. Maintenance - Routine inspections and preventative maintenance should be performed on all powered industrial trucks. Trucks found to be in need of repair should be removed from service until restored to a safe operating condition. Battery Charging - Battery-charging areas should be provided with local exhaust ventilation. Smoking should be prohibited in battery-charging areas. Strong acids (such as sulfuric acid) are used in batteries. To prevent injury, workers should wear protective clothing--such as rubber boots, a rubber apron, chemical goggles, face shields, and rubber gloves--to guard against chemical splashes and burns. When charging batteries, acid should be poured into water; water should not be poured into acid. (this may result in an explosion). Battery-charging and chemical-handling areas should be provided with emergency eyewash facilities and safety showers capable of providing at least a 15-minute flush of running water. For additional information, see Occupational Safety Report OS-70-12, Emergency Eyewash Facilities and Safety Showers Additional information on powered industrial truck safety can be found at the following OSHA Web site link: OSHA Powered Industrial Trucks. Bloodborne Pathogens Protection OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) – This standard covers workers performing healthcare services who have a reasonable anticipation of exposure to human blood or other potentially infectious materials. The standard requires the development and implementation of a bloodborne pathogens exposure control plan that addresses the exposure by job classification and job tasks or procedures, and recommends the use of universal precautions. For further information on the OSHA standard, click on the following link: Bloodborne Pathogens Standard. Written Procedures - A written program should be established to control worker exposure to bloodborne pathogens. The program should include safe handling procedures, worker training, inspections, incident reporting, hepatitis B vaccinations, and PPE and clothes. PPE that should be made available to workers include: (1) disposable latex gloves (note: the use of latex gloves has recently become associated with an outbreak of allergic reactions, and substitutes should be provided where indicated); (2) disposable facemasks, goggles, or face shields; (3) gowns or other protective garments impervious to liquids; and (4) head and shoe covers. Noise General - In a bowling center with hard materials on the ceiling, walls, and floor, almost all the sound that strikes the surfaces is reflected. The sound level goes down as you move away from the source, but after a certain point it decays very slowly and remains virtually unchanged. A better sound environment can be obtained by covering the ceiling and walls with sound-absorbing material. A program should be implemented to evaluate and control workplace noise levels in pin setting and ball return areas, and other areas where high noise levels exist. If noise levels cannot be reduced by engineering controls, PPE should provided for workers exposed to excessive noise levels, as required by OSHA. Workplace Violence General - Nearly any business today is exposed to potential violence from customers, visitors, and from other workers. A workplace violence prevention program should be developed and implemented to address these exposures. The key to protecting workers from assaults by disgruntled customers (and strangers) in the workplace is to restrict access by unauthorized individuals. A clear and explicit policy that defines what unacceptable behavior by workers is, advises workers that threats and intimidation will not be tolerated under any circumstances, and spells out what disciplinary actions will be taken by the employer for violations should be established. The policy should provide for a grievance procedure for accused workers to defend themselves. Reviewed by legal counsel, the policy should stress both the company's commitments to a safe workplace and the need for workers to respect each other regardless of age, gender, race, creed, national origin, or position within the organization. The policy should be communicated to all workers. Recommendations - The first step in developing a workplace violence prevention program is to assess how vulnerable the company is to workplace violence and what preventative actions could be taken. Staff Reprinted with permission by Golden Eagle Insurance™ A U T O M O T I V E B O D Y S H O P S members who actually perform the tasks should participate in the development and testing of the procedures designated to protect employees. After developing the procedures and testing them, all employees should receive initial and recurring training to include robbery prevention training. Physical security should be made as complete as facilities and operational issues will allow. Limit cash on site and use "cash-control" safes. Put signs in windows to let robbers know about the cash control program and add security devices, such as closed circuit television systems and panic alarms. COPYRIGHT ©2004, ISO Services Properties, Inc. The information contained in this publication was obtained from sources believed to be reliable. ISO Services Properties, Inc., its companies and employees make no guarantee of results and assume no liability in connection with either the information herein contained or the safety suggestions herein made. Moreover, it cannot be assumed that every acceptable safety procedure is contained herein or that abnormal or unusual circumstances may not warrant or require further or additional procedure. Reprinted with permission by Golden Eagle Insurance™ 1 9