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ANNUAL ALLIANCE REPORT
The Occupational Safety and Health Administration (OSHA) and the
Independent Lubricant Manufacturers Association (ILMA)
April 20, 2006 |
I. Alliance Background
Date Signed
February 9, 2004
Evaluation Period
February 8, 2005 – February 7, 2006
Overview
The OSHA and ILMA Alliance is providing ILMA members and others with information, guidance, and
access to training resources to protect workers from exposure to metalworking fluids and industrial
hazards in the manufacturing environment.
Implementation Team Members
| OSHA: |
|
| |
|
Earl Hicks
Russell Jones
Jess McCluer
Ira Wainless |
Office of Outreach Services and Alliances (OOSA)
Office of Small Business Assistance
OOSA
Office of Science and Technology Assessment |
| |
|
| ILMA: |
|
| |
|
Jerry Burns
Adam Cramer
John Cutcher
Walter Dalby
John Howell
Rich Kraska
Jeffrey Leiter
Keith Nykerk
Kristin Pelliza
Carol Poole
Celeste Powers
Gene White |
Crescent Oil Company, Inc.
Government and Regulatory Counsel
D.A. Stuart Corp.
ExxonMobil Corporation
D.A. Stuart Corp.
Lubrizol Corp.
General Counsel
Fuchs Lubricants Co.
D.A. Steward Company
Quaker Chemical
Executive Director
Milacron |
II. Implementation Team Meetings
January 23, 2006
October 25, 2005
September 8, 2005
August 23, 2005
August 1, 2005
July 28, 2005
July 27, 2005
June 7, 2005
March 15, 2005
February 15, 2005 |
Dermatitis Hazard Assessment Guide, Teleconference
Meeting, Teleconference
Small Business Roundtable, Washington, DC
Dermatitis Hazard Assessment Guide, Teleconference
Globally Harmonized Systems (GHS) Workgroup,
Washington, DC
Metalworking Fluid QUICKSTART Guide, Teleconference
Meeting, Teleconference
Metalworking Fluid QUICKSTART Guide, Teleconference
Meeting, Teleconference
OSHA Alliance Program Hazard Communication Roundtable, Washington, DC |
III. Results
- Events and Products
Training and Education
- Develop training and education programs on the safe and proper use of lubricant products.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
Outreach and Communication
- Develop and disseminate information through print and electronic media, including electronic
assistance tools and links from OSHA's and ILMA's Web sites.
Products
OSHA and ILMA Alliance Web site
OSHA is continuing to update the OSHA and ILMA Alliance Web page that is posted on the Agency's Web
site. It includes the OSHA and ILMA Alliance agreement, news releases, events and milestones and
successes.
ILMA Web site (www.ilma.org)
ILMA is continuing to update the section on its Web site which contains information on the OSHA and
ILMA Alliance. The section includes links to the Alliance agreement, OSHA and ILMA's press releases
and OSHA's Safety and Health Topics pages.
OSHA Safety and Health Topics page
The following Alliance implementation team member is continuing to participate on the OSHA
Metalworking Fluids Safety and Health Topics page's editorial board:
- Gene White, ILMA, Senior Environmental, Health, Milacron Consumable Products; Cincinnati, OH
Publications and Newsletters
Information on the activities of the OSHA and ILMA Alliance have appeared in a number of printed and
online publications, including: Alliance Quarterly Review, Compoundings
and FLASHPoint. For more information on the articles, see the “Alliance
Program Reach” table.
Metalworking Fluids (MWF) QUICKSTART Guide
In order to educate the public about the safe use of lubricants, the Alliance implementation team
developed a Metalworking Fluids (MWF) QUICKSTART Guide for Small Businesses, based on OSHA's
Compliance Assistance Quick Start. The MWF QUICKSTART Guide provides a brief step-by-step outline on
how to work safely with MWFs to help small businesses and their employees effectively manage the
health, safety and environmental impacts of MWFs. The guide was completed and posted on ILMA's Web
page in September 2005. A link to the guide was also posted on the OSHA Web site.
- Speak, exhibit, or appear at OSHA or ILMA events such as ILMA's Spring Management Forum, Fall
Annual Meeting, Safety, Health, Environmental and Regulatory Affairs (SHERA) Committee meetings, and
LubeCare® Workshops.
Events
ILMA Annual Conference, October 15-19, 2005, Orlando, Florida
On October 16, 2005, Lee Anne Jillings, Director, Office of Outreach Services and Alliances, gave a
presentation on the Alliance Program and the activities of the OSHA and ILMA Alliance, OSHA's
cooperative programs and OSHA's enforcement activities to 200 attendees at ILMA's Annual Conference.
OSHA also provided compliance assistance materials and information on OSHA and the Alliance Program,
including an OSHA and ILMA Alliance Activities Summary document, that were distributed at the event.
- Cross-train OSHA personnel and industry safety and health professionals in best practices or other
effective approaches, as jointly determined by OSHA and ILMA.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
- Promote and encourage ILMA members' participation in OSHA's cooperative programs such as
compliance assistance, the Voluntary Protection Programs, and Consultation and its Safety and Health
Achievement Recognition Program.
Consultation Program
Adam Cramer has made numerous presentations to the association regarding the Consultation Program,
including the association's Family Business Council during the 2005 ILMA Annual Conference in
Orlando, Florida.
- Share information on best practices in lubricant manufacturing and distribution, as jointly
determined by OSHA and ILMA, with others in the industry and promote awareness of occupational
hazards through ILMA's product stewardship program—LubeCare®.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
- Work with other Alliance Program participants on projects on industrial hazards related to metal
working and other health and safety issues that are addressed and developed through the Alliance
Program.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
- Encourage ILMA member companies to build relationships with OSHA's Regional and Area Offices to
address health and safety issues, including industrial hazards related to metal working.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
Promoting the National Dialogue on Workplace Safety and Health Goals
- Raise industry awareness and demonstrate their own commitment to workplace safety and health
whenever ILMA leaders address groups.
The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to
address this goal.
- Convene or participate in forums, round table discussions, or stakeholder meetings on lubricant
issues to help forge innovative solutions in the workplace or to provide input on safety and health
issues.
OSHA Alliance Program Hazard Communication Roundtable, Globally Harmonized Systems for
Classification and Labeling of Chemicals Workgroup
On February 15, 2005, representatives from ILMA participated in the Alliance Program's Hazard
Communication Roundtable for hazard communication-related National Alliances to discuss the
development of hazard communication compliance assistance resources that the Alliances would be
interested in working on together. The Globally Harmonized System for Classification and Labeling of
Chemicals (GHS) Workgroup was formed during the roundtable meeting.
GHS Workgroup – The GHS Workgroup met on August 1, 2005 to discuss the development and distribution
of resources to promote the GHS to small businesses. In 2006, OSHA plans to publish in the Federal
Register an Advanced Notice of Proposed Rulemaking revising its Hazard Communication Standard to
adopt the GHS.
- August 1, 2005 – ILMA staff members Adam Cramer, Jeffrey Leiter and ILMA member John Howell
attended the Workgroup meeting.
OSHA Small Business Roundtable
On September 8, 2005, Adam Cramer and Jeffrey Leiter, along with representatives from 16 other
Alliances met to provide feedback and input on the compliance assistance components of OSHA's Small
Business Initiative (SBI). The Roundtable attendees participated in four breakout groups to discuss
OSHA's Consultation Program, small business issues related to safety and health training, and OSHA's
printed materials and Web-based tools. During the Roundtable, the attendees provided OSHA with a
number of recommendations to enhance its small business compliance assistance activities and
resources.
- Executive Summary
Through the Alliance Program, OSHA and ILMA are continuing to work together to develop products for
small businesses to use in order to protect workers from metalworking fluids and industrial hazards
in the manufacturing environment. This positive relationship has led to the development of several
compliance assistance materials that the team is sharing with the public.
- The OSHA-ILMA implementation team developed a MWF QUICKSTART Guide for Small Businesses. The guide
provides a brief step-by-step outline on how to work safely with MWFs and is designed to help small
businesses and their employees effectively manage the health, safety and environmental impacts of
MWFs.
In addition, OSHA and ILMA representatives are sharing their expertise through participation on
OSHA's electronic assistance tools' editorial boards and speaking and exhibiting opportunities. For
example:
- Lee Anne Jillings, Director, Office of Outreach Services and Alliances, gave a presentation on
OSHA's cooperative programs and the activities of the OSHA-ILMA Alliance and enforcement activities
to 200 attendees on October 16, 2005 during the ILMA Annual Conference on October 15-19, 2005 in
Orlando, Florida.
- ILMA promoted the activities of the OSHA and ILMA Alliance and compliance assistance programs
through articles in its monthly publication, Compoundings and their weekly e-Newsletter FLASHPoint.
The articles focused on a number of topics such as the Alliance Program Hazard Communication
Roundtable and the Small Business Roundtable.
- ILMA participates on the Alliance Program's Hazard Communication Roundtable GHS Workgroup. The
Workgroup is discussing the development and distribution of resources to promote the GHS to small
business in anticipation of OSHA's revising its Hazard Communication Standard to adopt the GHS.
- ILMA participated on the OSHA Small Business Roundtable which provided a number of recommendations
for OSHA to enhance its small business compliance assistance activities and resources.
- An ILMA member serves on the editorial board of OSHA's Metalworking Fluids Safety and Health
Topics page.
Currently, ILMA members are in the process of developing several products for OSHA to review and
provide recommendations on in 2006. These include a Dermatitis Fact Sheet and a Lubricant Fact
Sheet. ILMA is also working with the Agency to develop an Alliance renewal agreement that will also
focus on Hazard Communication. ILMA is continuing to include articles regarding the OSHA and ILMA
Alliance through articles in their monthly publication, Compoundings and their weekly e-Newsletter
FLASHPoint. Finally, OSHA continues to recognize ILMA's Alliance Program Web site as a model for
other Alliances to use when they create an Alliance Program Web site to post on their Web page.
- Alliance Program Reach
| Type of Activity (Conference,
Training, Print and Electronic Distribution, etc.) |
Number of Individuals Reached or
Trained |
| OSHA and ILMA Alliance Web page on OSHA's Web site |
4,464 |
| ILMA Web site – Link to Alliance Agreement and
additional OSHA Web page links |
1,428 |
| Metalworking Fluids Safety and Health Topics page |
23,652 |
| December 2005 – "The Executive Director Update,"
Compoundings |
1,701 |
December 2005 Alliance Quarterly Review –
"ILMA Alliance Produces New Tool for Managing Metalworking Fluid Hazards"
"Roundtable Seeks Input to Enhance Small Business Safety and Health Efforts"
"New eTools, Safety and Health Topics pages Highlight OSHA's Alliance Program Fiscal '05 Safety
and Health Products Development" |
300 |
October 16, 2005 ILMA Annual Meeting, Orlando, FL
Speaker: Lee Anne Jillings, Director, Office of Outreach Services and Alliances, USDOL-OSHA |
200 |
| September 13, 2005 – "ILMA Participates in OSHA
Alliance Small Business Roundtable," FLASHPoint |
1,667 |
| September 2005 – "Alliance Workgroup Identifies
Compliance Assistance Tools," Alliance Quarterly Review |
300 |
| August 9, 2005 – "ILMA Attends OSHA Alliance
Roundtable on Globally Harmonized System," FLASHPoint |
1,667 |
| March 2005 – "Hazcom Roundtable Address MSDSs,
Compliance Assistance Issues," Alliance Quarterly Review |
300 |
| February 22, 2005 – "ILMA Attends OSHA HazCom
Roundtable," FLASHPoint |
1,667 |
| TOTAL |
37,346 |
IV. Upcoming Milestones
In the upcoming year, OSHA's and ILMA's positive relationship will continue to grow and the
implementation team will undertake a number of activities and develop a number of products. ILMA
will continue to work with OSHA and will sign an OSHA-ILMA Alliance renewal agreement. Through the
renewal agreement, OSHA and ILMA will continue to develop products for small businesses to use in
order to protect workers from metalworking fluids and industrial hazards in the manufacturing
environment. In addition, the renewal agreement will address hazard communication.
To meet the goals of the Alliance, ILMA will complete the Dermatitis Fact Sheet, which ILMA will
share with OSHA for feedback. The Alliance implementation team will also begin developing a
Lubricant Fact Sheet once the Dermatitis Fact Sheet is completed. In addition, an ILMA member will
continue to participate on the OSHA Metalworking Fluids Safety and Health Topics page's editorial
board.
Members of the association plan to participate on the Alliance Program's Hazard Communication
Roundtable's GHS Workgroup. The Workgroup will discuss developing and distributing resources to
promote the GHS to small businesses. In 2006, OSHA is planning to publish an Advanced Notice of
Proposed Rulemaking revising its hazard communication standard to adopt the GHS in the Federal
Register.
ILMA will work with OSHA to distribute products developed through the OSHA and ILMA Alliance to
specific trades within the manufacturing industry, including machinists. OSHA and ILMA are working
to identify the tasks that could be performed through both the OSHA Alliance Program and the Agency
to distribute and promote products developed through the OSHA Alliance Program.
OSHA and ILMA will also be promoting the Alliance Program and the Agency's compliance assistance
materials. ILMA plans to continue to promote OSHA compliance assistance materials, cooperative
programs such as the Consultation program and the OSHA-ILMA Alliance through articles in their
monthly publication, Compoundings and their weekly e-Newsletter
FLASHPoint. In addition, OSHA will promote the products the Alliance
produces in the AQR and through sending the information to OSHA's
Regional, Area Office, Consultation Program and State Plan State Representatives.
Report prepared by: Jess McCluer, Alliance Coordinator, Office of Outreach Services and Alliances,
April 20, 2006
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