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ALLIANCE ANNUAL REPORT

The Occupational Safety and Health Administration (OSHA) and the
Independent Lubricant Manufacturers Association (ILMA)
March 19, 2007

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

 
OSHA:  
   
Mark Hatch
Lee Anne Jillings
Russell Jones
Jess McCluer
Ira Wainless
Office of Health Enforcement
Office of Outreach Services and Alliances (OOSA)
Office of Small Business Assistance
OOSA
Office of Science and Technology Assessment
   
ILMA:  
   
Adam Cramer
John Howell
Rich Kraska
Jeffrey Leiter
Carol Poole
Celeste Powers
Gene White
Leiter & Cramer PLLC (ILMA Counsel)
D.A. Stuart Corp.
ILMA Toxicology Consultant
Leiter & Cramer PLLC (ILMA Counsel)
Quaker Chemical
Executive Director
Milacron


II. Implementation Team Meetings

 
February 1, 2007
October 11, 2006
August 18, 2006
February 27, 2006
February 14, 2006
Small Business Roundtable, Washington, DC
Dermal Assessment Guide, Teleconference
Dermal Assessment Guide, Teleconference
Dermal Assessment Guide, Teleconference
Meeting, Washington, DC

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 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

    • 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
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 6,106
ILMA Web site Link to Alliance Agreement and additional OSHA Web page links 964
Metalworking Fluids in Small Business: A Health and Safety QUICKSTART Guide on ILMA's Web page 2,020
Metalworking Fluids Safety and Health Topics page 24,711
May 25, 2006 "OSHA Renews Alliance with the Independent Lubricant Manufacturers Association," OSHA News Release 69 News Services
May 30, 2006 "ILMA Renews Alliance with OSHA," FLASHPoint 1,747
May 30, 2006 "OSHA, Lubricant Manufacturers Association Renew Alliance," Reliable Plant Magazine Data Not Available
June 1, 2006 "OSHA Renews Metalworking Fluid Makers Alliance," BNA Occupational Safety and Health Reporter Data Not Available
June 1, 2006 OSHA includes information on the OSHA/ILMA Alliance renewal signing in QuickTakes 52,805
June 5, 2006 "ILMA Renews Alliance with OSHA," OEM/Lube News Data Not Available
August 8, 2006 "Phone Scams Threaten OSHA Fines," FLASHPoint 1,747
November 6, 2006 National Safety Council's 2006 Congress and Expo, November 5-9, 2006, San Diego County Convention Center, San Diego, California

Speakers: 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
70
November 7, 2006 2006 National Safety Congress and Expo, November 5-9, 2006, San Diego County Convention Center, San Diego, California

Speakers: Lee Anne Jillings, Director, Office of Outreach Services and Alliances, USDOL-OSHA and John Howell, DA Stuart
10
December 5, 2006 "ILMA Highlights Participation in OSHA Alliance Program," FLASHPoint 1,747
January 2, 2007 "ILMA Publishes Dermal Assessment Guide as Part of OSHA Alliance," FLASHPoint 1,747
January 10, 2007 "ILMA Publishes Dermal Assessment Guide as Part of OSHA Alliance," OEM/Lube News Data Not Available
TOTAL 93,674

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