The Occupational Safety and Health Administration (OSHA) and the
Independent Lubricant Manufacturers Association (ILMA)

I. Alliance Background

Date Signed

February 9, 2004

Evaluation Period

February 8, 2006 - February 7, 2007

Date Renewed

May 23, 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
 

II. Implementation Team Meetings  

III. Results

1. Events and Products
   
   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 page
   
   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 agreement, news releases, activities and events and milestones and successes. During the reporting period a link to ILMA's Dermal Assessment Guide on ILMA's Web Site was added to the Web page. The guide is a product of the OSHA and ILMA Alliance.
   
   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 print and online publications, including: BNA Occupational Safety and Health Reporter, ILMA's FLASHPoint, OEM/Lube News, and Reliable Plant. For more information on the articles, see the "Alliance Program Reach" table.
   
   Dermal Assessment Guide
   
   Through the OSHA and ILMA Alliance, ILMA developed the Dermal Assessment Guide as a tool to help small businesses understand the possible connection between employee dermatitis and facility operations that use metal removal fluids. The guide covers Machining Operation Variables, Metal Removal Fluid Variables, Engineering and Environmental Parameters, Personal Protective Equipment and Skin Care, Employee Feedback and other Considerations in relation to the potential for skin irritation. The guide was completed and posted on ILMA's Web site in January 2007. OSHA posted a link to the guide on the OSHA and ILMA Alliance Web page of OSHA's 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
   
   National Safety Council's 2006 Congress and Expo, November 5-9, 2006, San Diego County Convention Center, San Diego, California.
   
   On November 6, 2006, Barnett Lawrence, Compliance Assistance Coordinator, Office of Outreach Services and Alliances, Directorate of Cooperative and State Programs (DCSP), USDOL-OSHA, Cathy Cronin, Chief, Division of Training and Educational Development, Office of Training and Education, DCSP, USDOL-OSHA, and ILMA member Carol Poole, Quaker Chemical presented "Getting the Most Out of OSHA's Web Site" to 70 attendees.
   
   On November 7, 2006, Lee Anne Jillings, Director, Office of Outreach Services and Alliances, USDOL-OSHA; and ILMA representative John Howell, DA Stuart Lorp, along with Bill Erny, American Petroleum Institute and representing the Safe Tank Alliance, spoke to 10 attendees about training products developed through the Alliance Program in a workshop entitled, "Success of the Alliance Program: Best Practices."
    
   • 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 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.
     
     The OSHA and ILMA Alliance Implementation Team has not started work on programs or projects to address this goal in a structured manner, but informal efforts to educate ILMA members about these programs have been explored.
      
   • 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
    
   • 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.
   Promoting the Globally Harmonized System for the Classification and Labeling of Chemicals (GHS) Workgroup, October 25, 2006, Washington, DC
   
   ILMA representatives participated in the October 25, 2006 Alliance Program Hazard Communication Roundtable's Promoting the GHS Workgroup meeting, in Washington, DC. During the Workgroup meeting, representatives from 15 Alliance Program participants identified compliance assistance tools and products to educate the public, particularly small businesses, about the GHS. They also provided recommendations on the target audiences, subjects and formats of and methods for distributing the information. The meeting was held as a follow-up to the February 15, 2005 Alliance Program Hazard Communication Roundtable and the August 1, 2005 promoting the Globally Harmonized System for the Classification and Labeling of Chemicals Workgroup meeting.
   
   OSHA Small Business Roundtable
   
   On February 1, 2007, Adam Cramer and representatives from five Alliances and OSHA and On-site Consultation Program representatives participated in the OSHA Small Business Roundtable. During the meeting, the Alliance Program participants were updated on the status of the recommendations to enhance small business compliance assistance activities and resources that they provided during the September 8, 2005 Roundtable meeting. The Roundtable also reviewed new training resources that were developed by the Florida On-site Consultation Program and OSHA Training Institute.
    
2. Executive Summary
   
   Through the Alliance Program, OSHA and ILMA are continuing to work together to develop products for small businesses to use to protect workers from metalworking fluids and industrial hazards in the manufacturing environment. This positive relationship has led to the development of the many programs and projects that the team is currently working on or has produced. For example, the OSHA-ILMA implementation team developed a Dermal Assessment Guide. The guide is designed to help small businesses understand the possible connection between instances of employee dermatitis and facility operations that use metal removal fluids. The guide was completed and posted on ILMA's Web site and linked to the OSHA and ILMA Alliance Web page of OSHA's Web site in January 2007.
   
   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:
    
   • Barnett Lawrence, Compliance Assistance Coordinator, Office of Outreach Services and Alliances, USDOL-OSHA; Cathy Cronin, Chief, Division of Training and Educational Development, Office of Training and Education, USDOL-OSHA; and Carol Poole, Quaker Chemical presented "Getting the Most Out of OSHA's Web Site" to 70 attendees at the NSC's 2006 Congress and Expo.
      
   • Lee Anne Jillings, Director, Office of Outreach Services and Alliances, USDOL-OSHA and John Howell, ILMA, along with another Alliance participant, Bill Erny, American Petroleum Institute and representing the Safe Tank Alliance spoke to 10 attendees about training products developed through the Alliance Program in a workshop entitled, "Success of the Alliance Program: Best Practices" at the NSC's 2006 Congress and Expo.
      
   • ILMA continues to participate on the Alliance Program's Hazard Communication Roundtable's Promoting the GHS Workgroup.
      
   • ILMA continues to participate on the OSHA Small Business Roundtable that provides a forum for Alliance participants to discuss and provide comments on OSHA-developed informational products that will provide enhanced compliance assistance information to the small business community.
      
   • An ILMA member continues to serve on the editorial board of OSHA's Metalworking Fluids Safety and Health Topics page.
      
   • ILMA promoted the activities of the OSHA and ILMA Alliance and compliance assistance programs through articles in their weekly e-Newsletter FLASHPoint.
   Finally, OSHA and ILMA committed to continuing the Alliance and signed an Alliance renewal agreement on May 23, 2006.
    
3. Alliance Program Reach

IV. Upcoming Milestones

The OSHA and ILMA Alliance Implementation Team has discussed a number of activities that will be undertaken in the upcoming year. For example, the Alliance implementation team will begin developing a Lubricant Fact Sheet. 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 also plan to continue participating in the Alliance Program's Hazard Communication Roundtable's Promoting the GHS Workgroup which is discussing developing and distributing resources to promote the GHS to small businesses.

ILMA plans to continue to promote OSHA compliance assistance materials, cooperative programs and the OSHA and ILMA Alliance through articles in their monthly publication, Compoundings and their weekly e-Newsletter FLASHPoint.

For example, the association invited OSHA's Assistant Secretary Edwin G. Foulke, Jr., to write an article for the March 2007 issue of Compoundings describing OSHA's compliance assistance resources and cooperative program activities including the OSHA and ILMA Alliance. An article describing the Dermal Assessment Guide will also be included in the issue.

Finally, ILMA will continue discussions with the Safe Tank Alliance regarding the potential development of joint Alliance projects and products.


Report prepared by: Jess McCluer, Alliance Coordinator, Office of Outreach Services and Alliances, March 19, 2006