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

1. Alliance Background

   Date Signed
   
   February 9, 2004
   
   Dates Renewed
   
   May 23, 2006; May 13, 2008
   
   Evaluation Period
   
   February 9, 2009 – February 8, 2010
   
   Overview
   
   Through the OSHA and ILMA Alliance, OSHA and ILMA are working together to encourage employers, including small businesses, to increase employee access to safety and health information and training resources, particularly in reducing and preventing exposure to industrial hazards in the manufacturing environment.
   
   Implementation Team Members

   OSHA:

   Eric Lahaie**

   Office of Outreach Services and Alliances (OOSA),
   Directorate of Cooperative and State Programs (DCSP)

   Russell Jones

   Office of Small Business Assistance, DCSP

   Tony Mapes*

   OOSA, DCSP

   Elizabeth (Bea) Way

   OOSA, DCSP

   ILMA:

   John Burke

   Chair, Safety, Health, Environmental, and Regulatory Affairs (SHERA) Committe

   Adam Cramer

   Leiter & Cramer, PLLC (ILMA Counsel)

   John Howell

   D.A. Stuart Corp.

   Rich Kraska

   ILMA Toxicology Consultant

   Jeffrey Leiter

   Leiter & Cramer PLLC (ILMA Counsel)

   Cathy Novak

   Eastern Oil (ILMA President)

   Debbie Purnell-Otey

   The Dow Chemical Company (SHERA Committee Chair)

   Celeste Powers

   Executive Director

   Gene White

   Milacron

2. Implementation Team Meetings

   February 27, 2009

   Implementation Team Meeting

   June 23, 2009

   Implementation Team Meeting

   November 4, 2009

   Implementation Team Meeting

   In addition to these formal meetings, the Alliance coordinators from both groups maintained regular contact throughout the reporting period to monitor the Alliance's progress and results.

3. Results

   1. Events and Products
      
      Outreach and Communication
       
      • Work with OSHA to provide expertise in developing information on the recognition and prevention of workplace hazards, and to provide expertise in developing ways of communicating such information (e.g., print and electronic media, electronic assistance tools and OSHA's and ILMA's Web sites) to employers and employees in the industry.
        
        Products
        
        Lubricant Fact Sheet
        
        Through the Alliance, ILMA is developing a Lubricant Fact Sheet. The association will share the draft with OSHA for review and feedback when it is completed.
        
        ILMA and OSHA Alliance-Related Web Page
        
        ILMA is continuing to update the sections on its Web site, which contains information on the OSHA and ILMA Alliance. The sections include links to the Alliance agreement, Alliance-developed products, OSHA and ILMA press releases and OSHA's Safety and Health Topics pages.
        
        OSHA and ILMA Alliance Web page
        
        OSHA is continuing to update the OSHA and ILMA Alliance Web page that is posted on the OSHA Web site. The page includes the OSHA and ILMA Alliance agreement, renewal agreements, annual reports, news releases, information on activities and events, milestones and successes of the alliance, and links to resources developed by ILMA through the Alliance Program.
        
        Publications and Newsletters
        
        Information on OSHA activities and compliance updates has appeared in a number of ILMA's e-Newsletter the FLASHPoint. Articles include compliance assistance and changes in enforcement.
        
        OSHA Safety and Health Topic Pages
        
        Representatives from ILMA serve on the editorial boards of the following OSHA Safety and Health Topics pages, providing OSHA with their expertise and technical review:
        • Making the Business Case for Safety and Health
          • Carol Poole, Health and Safety Specialist, Quaker Chemical Corporation, Conshohocken, PA
        • Metalworking Fluids
          • Gene White, PhD, MS, Manager, Environmental Science, Milacron, Inc., Cincinnati, OH
      • Speak, exhibit, or appear at OSHA's or ILMA's conference, meetings or workshops including ILMA's Spring Management Forum; Fall Annual Meeting; and Safety, Health, Environmental and Regulatory Affairs (SHERA) Committee meetings.
        
        The OSHA and ILMA Alliance Implementation Team have not started work on programs or projects to address this goal.
         
      • Share information among OSHA personnel and industry safety and health professionals regarding ILMA's best practices or effective approaches and publicize results through outreach by ILMA and through OSHA- or ILMA-developed materials, training programs, workshops, seminars and lectures (or any other applicable forum).
        
        The OSHA and ILMA Alliance Implementation Team have not started work on programs or projects to address this goal.
      • Promote to the ILMA members the benefits of OSHA's cooperative programs: such as compliance assistance, the Voluntary Protection Programs, On-site Consultation Program and its Safety and Health Achievement Recognition Program.
      • ILMA FLASHPoint enewsletter
        
        Through the OSHA and ILMA Alliance, ILMA published the following articles in their FLASHPoint enewsletter promoting OSHA's On-site Consultation Program and various OSHA compliance assistance resources:
        • April 28, 2009 – "OSHA Notifies Workplaces With High Injury and Illness Rates"
        • May 5, 2009 – "OSHA Changes Enhanced Enforcement Program"
        • May 26, 2009 – "Proposed GHS Rule from OSHA Now on the Way"
        • June 9, 2009 – "Strategic Health and Safety Alliance Planned"
        • June 30, 2009 – "OSHA Offers Tips on Working Safely in Hot Weather"
        • August 4, 2009 – "OSHA Program Targets Hazardous Chemical Workplaces"
        • September 15, 2009 – "OSHA Updates Eye/Face/Foot PPE Standards"
        • September 29, 2009 – "Flash-OSHA GHS Proposal Out Tomorrow"
        • October 6, 2009 – "OSHA Proposes GHS Rule-All ILMA Members Affected"
        • October 20, 2009 – "OSHA Initiating New NEP on Recordkeeping"
        • January 19, 2010 – "OSHA Announces "Listening" Session"
        • February 2, 2010 – "OSHA Proposes Recordkeeping Change to Improve Illness Data"
      
      
      • Work with other Alliance participants on specific issues and projects on manufacturing industrial hazards that are addressed and developed through the Alliance Program.
        
        The OSHA and ILMA Alliance Implementation Team have not completed work on programs or projects to address this goal.
      National Dialogue on Workplace Safety and Health Goal
       
      • Convene or participate in forums, roundtable discussions or stakeholder meetings on manufacturing industrial hazards and hazard communication to help forge innovative solutions in the workplace.
        
        Event
        
        2009 North American Occupational Safety and Health (NAOSH) Week, May 3-9, 2009, Washington, DC
        
        The Independent Lubricant Manufacturers Association and more than 55 other Alliance Program participants supported 2009 NAOSH Week. Sponsored annually by the American Society of Safety Engineers, an Alliance Program participant, and the Canadian Society of Safety Engineering, the Week focuses on the importance of preventing injuries and illnesses in the workplace. The theme for 2009 NAOSH Week was "Safety Means Always Coming Home."
   2. Executive Summary
      
      As a result of the Alliance's successes over the past six years, OSHA and ILMA will continue to work together to increase employer and employee access to training resources that address safety and health issues related to the lubricants industry. The positive and collaborative relationship has led to the development of the many programs and projects that the OSHA and ILMA Alliance Implementation Team are currently working on or have produced and published on ILMA's Web site. For example, through the Alliance, ILMA is currently in the process of developing a Lubricant Fact Sheet that will address how to work with lubricants safely. ILMA continues to update members on OSHA compliance and enforcement activities through its weekly e-newsletter.
       
   3. 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 the OSHA Web site	Data Not Available
   ILMA and OSHA Alliance Web page on the ILMA Web site	592
   Metalworking Fluids in Small Business: A Health and Safety QUICKSTART Guide on ILMA’s Web page	438
   Dermal Assessment Guide: A Health and Safety Guide for Dermatitis on ILMA’s Web site	784
   Safe Tank Entry Brochure on ILMA’s Web page	835
   OSHA Making the Business Case for Safety and Health Topics Page	13,271
   OSHA Metalworking Fluids Safety and Health Topics Page	8,492
   Metalworking Fluids: Safety & Health Best Practices Manual	15,030
   TOTAL	39,442

4. Upcoming Milestones

   In the upcoming year, the OSHA and ILMA Alliance Implementation Team will continue to work together to develop resources for small businesses to protect workers from metalworking fluids and industrial hazards in the manufacturing environment. The Implementation Team will finalize the draft Lubricant Fact Sheet and publish the resource on the alliance Web pages. In addition, the OSHA and ILMA Implementation Team will work with OSHA and the Society of Chemical Hazard Communication to promote the GHS and participate on a Hazard Communication Roundtable after OSHA publishes the Notice of Proposed Rulemaking.

   As part of the Alliance's outreach efforts, ILMA representatives will be joining with other Alliance Program participants to support 2010 North American Occupational Safety and Health Week, May 2-8, 2010. ILMA representatives also will continue to provide OSHA their expertise in serving on the editorial boards of the Making the Business Case for Safety and Health and Metal Working Fluids Safety and Health Topics page.

   Report prepared by: Morgan Seuberling, Safety and Occupational Health Specialist, Office of Outreach Services and Alliances, March 9, 2010.