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ANNUAL ALLIANCE REPORT

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

May 7, 2009

I. Alliance Background

Date Signed

February 9, 2004

Dates Renewed

May 23, 2006; May 13, 2008

Evaluation Period

February 9, 2008 February 8, 2009

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. In addition, the OSHA and ILMA Alliance Implementation Team will work on developing resources to address hazard communication and safety and health issues related to above ground storage tanks.

Implementation Team Members

 
OSHA:  
   
Russell Jones

Tony Mapes*
Lisa Ramber**
Elizabeth (Bea) Way
Office of Small Business Assistance,
Directorate of Outreach Services and Alliances (DCSP)
Office of Outreach Services (OOSA), DCSP
OOSA, DCSP
OOSA, DCSP
   
ILMA:  
   
John Burke

Adam Cramer
John Howell
Rich Kraska
Jeffrey Leiter
Carol Poole
Celeste Powers
Gene White
Chair, Safety, Health, Environmental,
and Regulatory Affairs (SHERA) Committee
Leiter & Cramer, PLLC (ILMA Counsel)
D.A. Stuart Corp.
ILMA Toxicology Consultant
Leiter & Cramer PLLC (ILMA Counsel)
Quaker Chemical
Executive Director
Milacron

* Tony Mapes has been serving as the Alliance Coordinator since January 22, 2008.
** Lisa Ramber is no longer with OSHA as of August 2009.

II. Implementation Team Meetings

 
May 7, 2008
May 13, 2008
May 16, 2008
July 29, 2008
August 27, 2008
Conference call to discuss Safe Tank Entry Brochure
Implementation Team Meeting
Conference call to discuss Safe Tank Entry Brochure
Conference call to discuss Safe Tank Best Practices Seminar
Conference call to discuss Safe Tank Best Practices Seminar

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

III. 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 OSHAs and ILMAs Web sites) to employers and employees in the industry.

      Products

      Safe Tank Entry: When Entering Aboveground Storage Tanks Brochure


      The OSHA and ILMA Alliance Implementation Team worked with the OSHA and Safe Tank Alliance through the Alliance Program to develop the "Safe Tank Entry: When Entering Aboveground Storage Tanks" brochure. The brochure provides information for employers and employees for hazards such as falls and confined space entry in above ground storage tanks.

      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.

      OSHA Safety and Health Topics 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
      • Metal Working Fluids
        • Gene White, PhD, MS, Manager, Environmental Science, Milacron, Inc., Cincinnati, OH

      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. It includes the OSHA and ILMA Alliance agreement, renewal agreement, news releases, products and resources, activities and events and milestones and successes.

      ILMA Web site

      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 OSHAs Safety and Health Topics pages.

      Publications and Newsletters

      Information on the activities of the OSHA and ILMA Alliance have appeared in a number of print and online publications, including: ILMAs FLASHPoint, and Compoundings. For more information on the articles, see the "Alliance Program Reach" table.

    • Speak, exhibit, or appear at OSHAs or ILMAs conference, meetings or workshops including ILMAs Spring Management Forum; Fall Annual Meeting; and Safety, Health, Environmental and Regulatory Affairs (SHERA) Committee meetings.

      Events

      3rd Symposium on the Assessment and Control of Metal Removal Fluids, October 5-8, 2008, Dearborn, Michigan


      On October 6, 2008, Elaine M. Clapp, M.S., Safety and Health Manager, Michigan Occupational Safety and Health Administration (MIOSHA), gave a presentation entitled "Overview of OSHA and State Plan State Enforcement Activities Involving Metalworking Fluids," to 40 attendees during the symposium.

    • Share information among OSHA personnel and industry safety and health professionals regarding ILMAs 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).

      Events

      OSHA On-site Consultation Training Conference, April 28-May 1, 2008, Seattle, Washington


      On April 30, 2008, Lee Anne Jillings, then-Director, Office of Outreach Services and Alliances, Directorate of Cooperative and State Programs, USDOL-OSHA, presented an overview of the OSHA and ILMA Alliance and John K. Howell, Safety, Health, and Environmental Specialist, D.A. Stewart Company discussed tools and resources that have been developed through the Alliance Program in a workshop entitled, "Safety and Health Tools for Down-stream Users for Metal Working Fluids" to 29 attendees during the On-site Consultation Training Conference.

      Products

      Dermal Assessment Guide


      During the reporting period, ILMA promoted the "Dermal Assessment Guide" to its members by informing them and their customers that the guide can be downloaded from the ILMA and OSHA Alliance Web page on the ILMA Web site. The guide, which was produced as a product of the OSHA and ILMA Alliance, has been recognized by the metalworking fluid industry as a valuable resource.

    • Promote to the ILMA members the benefits of OSHAs 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

      ILMA published the following articles in their FLASHPoint enewsletter promoting OSHAs On-site Consultation Program, Safety and Health Achievement Recognition Program (SHARP), Voluntary Protection Programs (VPP), and various OSHA compliance assistance resources:

      • November 11, 2008 "OSHA Forum Discusses Small Business Compliance Challenges"
      • December 2, 2008 "OSHA Programs Helped to Reduce Injury/Illness Rates"
      • January 13, 2009 "OSHA Revises Voluntary Protection Programs"

    • Work with other Alliance participants on specific issues and projects on manufacturing industrial hazards that are addressed and developed through the Alliance Program.

      Safe Tank Entry: When Entering Aboveground Storage Tanks Brochure

      The OSHA and ILMA Alliance Implementation Team worked with the OSHA and Safe Tank Alliance through the Alliance Program to develop the "Safe Tank Entry: When Entering Aboveground Storage Tanks" brochure. The brochure provides information for employers and employees for hazards such as falls and confined space entry in above ground storage tanks.
       
    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

      3rd Symposium on the Assessment and Control of Metal Removal Fluids, October 6-8, 2008, Dearborn, Michigan


      ILMA, along with other trade associations and professional societies, hosted the 3rd Symposium on the Assessment and Control of Metal Removal Fluids, October 6-8, 2008 in Dearborn, Michigan. The event focused on safety, health, and sustainability issues in metalworking fluids. Conference participants included end-users and suppliers of metalworking fluids as well as government and academic representatives from around the world. In addition, representatives from OSHAs Region V and MIOSHA attended the symposium by invitation from ILMA. OSHA also provided compliance assistance publications for distribution to the seminar attendees.
       
  2. Executive Summary

    As a result of the Alliances successes in its first four years, OSHA and ILMA signed a Alliance renewal agreement on May 13, 2008. OSHA and ILMA will continue to work together to increase employer and employee access to training resources that address hazard communication and safety and health issues related to above ground storage tanks. 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 has produced. For example, OSHA and ILMA worked with the OSHA and Safe Tank Alliance to develop the Safe Tank Entry: When Entering Aboveground Storage Tanks brochure. The brochure provides information to small businesses for hazards such as falls and confined space entry for above ground storage tanks.

    As part of their outreach efforts, John K. Howell, Safety, Health, and Environmental Specialist, D.A. Stewart Company, made a presentation at OSHAs On-site Consultation Training Conference on April 30, 2008. ILMA also invited Elaine M. Clapp, M.S., Safety and Health Manager, MIOSHA, to make a presentation at the 3rd Symposium on the Assessment and Control of Metal Removal Fluids on October 6, 2008. In addition, ILMA invited federal OSHA and MIOSHA staff to attend the symposium free of charge.

  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 2,056
ILMA and OSHA Alliance Web page on the ILMA Web site 1,708
Metalworking Fluids in Small Business: A Health and Safety QUICKSTART Guide on ILMAs Web page 2,588
Dermal Assessment Guide: A Health and Safety Guide for Dermatitis on ILMAs Web site 1,441
OSHA Making the Business Case for Safety and Health Topics Page 11,519
OSHA Metalworking Fluids Safety and Health Topics Page 6,512
April 30, 2008 - OSHA On-site Consultation Training Conference, April 28-May 1, 2008, Seattle, Washington

Speakers: Lee Anne Jillings, then-Director, Office of Outreach Services and Alliances, Directorate of Cooperative and State Programs, USDOL-OSHA, presented an overview of the OSHA and ILMA Alliance and John K. Howell, Safety, Health, and Environmental Specialist, D.A. Stewart Company discussed tools and resources that have been developed through the Alliance Program in a workshop entitled, "Safety and Health Tools for Down-stream Users for Metal Working Fluids."
29
May 13, 2008 "ILMA Renews Alliance with OSHA for Second Time," Fuels and Lubes Data not available
May 22, 2008 "ILMA and OSHA Alliance Renewed for Second Time," ThomasNet Industrial Newsroom Data not available
May 23, 2008 "OSHA continues its Alliance with the Independent Lubricant Manufacturers Association," OSHA News Release 69
May 29, 2008 "OSHA Renews Metalworking Fluid Maker Alliance," BNA Occupational Safety and Health Reporter Data not available
May/June 2008 "OSHA, Lubricant Manufacturers Group Renew Alliance," ReliablePlant Data not available
June 3, 2008 "John Howell represents ILMA at OSHA Employee Conference," FLASHPoint 1,970
June 12, 2008 "OSHA Continues Its Alliance with the Independent Lubricant Manufacturers Association," Compliance Home Data not available
June 2008 "ILMA Renews Alliance with OSHA," Compoundings 2,000
July 1, 2009 "OSHA Representative to Speak at ILMA Annual Meeting," News Manager Data not available
October 6, 2008 - 3rd Symposium on the Assessment and Control of Metal Removal Fluids, October 5-8, 2008, Dearborn, Michigan

Speaker: Elaine M. Clapp, M.S., Safety and Health Manager, MIOSHA, gave a presentation entitled "Overview of OSHA and State Plan State Enforcement Activities Involving Metalworking Fluids."
40
TOTAL 29,932

IV. 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 and hazards associated with above ground storage tanks. For example, the Implementation Team will finalize the draft Lubricant Fact Sheet. In addition, the OSHA and ILMA Implementation Team will work with the OSHA and Safe Tank Alliance to conduct a Safe Tank Entry Workshop during the next reporting period.

As part of the Alliances outreach efforts, ILMA representatives will be joining with other Alliance Program participants to support 2009 North American Occupational Safety and Health Week, May 3-9, 2009. 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: Tony Mapes, Safety and Occupational Health Specialist, Office of Outreach Services and Alliances, May 6, 2009