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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
  1. 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 programLubeCare.

      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.

  2. 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.

  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 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