On-Site Consultation Develops Relationship with the New Jersey Gasoline-Convenience-Automotive Association

In April 2017, following an Occupational Safety and Health Administration (OSHA) enforcement inspection at a member’s site, representatives of the New Jersey Gasoline-Convenience-Automotive Association (NJGCA) contacted the New Jersey Department of Labor and Workforce Development, On-Site Consultation Program, seeking safety and health assistance for their members.  The OSHA, On-Site Consultation Program, offers no-cost and confidential occupational safety and health services to small and medium-sized businesses in all 50 states, the District of Columbia, and several U.S. territories, with priority given to high-hazard worksites. On-Site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies, such as the New Jersey Department of Labor or universities, work with employers to identify workplace hazards, provide advice for compliance with OSHA standards, and assist in establishing and improving safety and health programs.

Founded in 1937, this association represents over 1,500 small business owners who operate gasoline service stations, convenience stores, automotive parts stores, automotive repair shops, car washes, and car dealerships. The association advocates for effective public policies with legislators and state officials, offers small business services to their members, informs and educates members on industry matters, enhances general awareness and projects a positive image to the general public and media, and promotes the highest levels of ethical standards and professionalism among the members.

Following the association’s initial contact with the NJ On-Site Consultation Program, a consultation visit to a member’s site to evaluate safety and health hazards was planned. The member site asked the Director of Member Services for the association to join the consultation visit to learn about the consultation process and the assistance available.

Following the consultation visit, management staff from the NJ On-Site Consultation Program met with the NJGCA Executive Director. As a result of that meeting, an article was published in the association’s quarterly newsletter, “On the Road.” This article, highlighting the services of the free on-site consultation and the benefits of a consultation visit, was published in January 2018 and again in April 2019.

As a result of these articles, 23 members of NJGCA requested on-site consultation visits for their sites that included assessments by a safety consultant and an industrial hygienist. Through these visits, consultants educated members on the types of safety and health hazards commonly found in these industries. Below is a list of the top 10 most common safety and health hazards found at these facilities and the number of instances of each hazard documented during the consultation visits:

  1. Hazard Communication (47 instances) – Hazard Communication is a standard written to address chemical safety in the workplace. Employers need to have a written program, safety data sheets (SDS) for chemicals found onsite, clearly labeled chemicals, and provide employee training.
  2. Machine Guarding (32 instances) – Many types of equipment found in garages need guarding to prevent employees from being injured. Common types include bench grinders, drill presses, and compressed air belts.
  3. Electrical Safety (12 instances) – Electrical safety addresses a wide range of hazards related to the potential for employees to be electrocuted or injured by electrically ignited fires. Common issues include improper use of extension cords, overloaded circuits, and unguarded live parts.
  4. Fire Extinguishers (12 instances) – Employees who are expected to use fire extinguishers must be trained annually. The extinguishers must be visually inspected monthly and subject to an annual maintenance inspection.
  5. Personal Protective Equipment (PPE) (12 instances) – PPE must be worn as designated by the employer to protect employees from potential hazards. Commonly used PPE includes eye protection, hearing protection, and foot protection. The employer needs to develop a PPE Hazard Assessment, which clarifies what PPE must be worn for each hazardous task.
  6. Egress and Emergency Planning (6 instances) – Some examples are blocked emergency exits, inoperable emergency lighting, and failure to have an emergency action plan.
  7. Welding Safety (5 instances) – Welding presents both physical and health hazards to employees. Common concerns include storing fuel gases and oxygen too close together, not removing flammable material from a welding area, and failure to provide a 30-minute fire watch following welding activity.
  8. Control of Hazardous Energy (Lock Out /Tag Out) (4 instances) – Lock Out /Tag Out (LOTO) was developed to prevent employee exposure to uncontrolled energy sources found in equipment during repair or maintenance. Energy sources include electric, pneumatic, and hydraulic. For example, when the electricity is shut off, an employee can safely work in an area where live electrical parts would normally create an electrocution hazard. To comply with LOTO, employers need to have a written program, equipment specific procedures, and provide employee training.
  9. Eyewash Stations (3 instances) – Eyewash stations must be accessible and in working condition. They are required when employees may be exposed to corrosive chemicals, such as battery acid.
  10. Compressed Gas Storage (2 instances) – Compressed gas cylinders must be secured to prevent them from tipping over. Ideally, these are stored in a cabinet or chained to a wall.

Here are some comments from members of the NJGCA that participated in the NJ On-Site Consultation Program sharing their experiences:

As a 37-year owner of an Automotive Service Center, I have always taken great pride and responsibility in keeping my shop as clean and safe as possible. The OSH On-Site Consultation Program was a great test to see how our shop was performing in our daily safety and compliance issues. Both inspectors were great, well trained, and helped us understand all of the safety check lists that they performed. Our assessment went quite well, but we still had a couple of items that were not up to code. We repaired those items immediately, and we are very happy we scheduled our visit. I would recommend this program to all my automotive colleagues.

~ Automotive Service Center Owner, Lavallette, NJ

I was very impressed with the professionalism and personal commitment to safety and education displayed by both of the OSHA staffers that visited us. In over 40 years in business, this was the first direct contact with OSHA I’d ever had. My skepticism, and even a bit of fear, was quickly dispelled by the friendly, “here to help” way each staffer engaged me and my crew on each of their two visits. Some of the simple safety suggestions they gave had never occurred to any of us and were easy to implement. I wish that my insurance carrier’s annual inspections had included some education like this.

~ Gasoline Service Center Owner, Cape May, NJ

My brother met with you for the walk-through, and he felt that you handled it professionally. We were glad to find out that there were no outstanding issues that needed to be addressed. 

~ Gasoline Service Center President, Chestnut Ridge, NJ

“We greatly appreciate this positive feedback,” said Baker. “Inviting a state agency into your facility can be intimidating. Hopefully these NJGCA members’ positive experiences will dispel any concerns you have.”

To locate the OSHA On-Site Consultation Program nearest you, call 1-800-321-OSHA (6742) or visit www.osha.gov/consultation.

Source: Justin Baker, NJ On-Site Consultation Program, Chief Occupational Health