What Does OSHA Say About Detailing Bays
We recently contacted OSHA to get their thoughts about detailing and OSHA Compliance. We wanted to make sure we had answers on several questions that come up again and again. This post was originally made in 2024 and has been republished. Keep in mind OSHA rules and regulations change and that compliance is your responsibility.
What We Wanted to Know About OSHA and Detailing Bays
Table of Contents
One of the main points of confusion is labeling. The requirement, as I understand, is that bottles that are not for immediate use must be labeled, but what does that mean?
The hazard communication has a definition for immediate use, and it states, “ Immediate use means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.” Any bottle that will be used over time must be labeled.
For example, is the handwritten product type enough for a spray bottle? What about product type and brand name? Do they need full labels like you would find on a retail bottle?
The labels must contain product identifiers and words, pictures, or a combination of them. Please refer to this letter of interpretation Labeling of Secondary Containers | Occupational Safety and Health Administration (osha.gov)
Here is the standard regarding labeling in the workplace:
1910.1200(f)(6)
Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:
(i) The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or,
(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
Please note that the Hazard Communication Standard is about to change. The change becomes effective July 19, 2024.
This document may also be helpful once the effective date is here:
SDS sheets are similarly confusing to my customers. Is a QR code with a link to all chemicals sufficient? Do they need a printed binder?
The above-mentioned letter of interpretation also addresses SDSs. These do not need to be in printed form, but they must be immediately available to the employees. The employer can use a QR code as long as all employees have cell phones that they are willing to use for work. This means if the employee does not want to use a personal cell phone to access the SDSs the employer must provide another way to access the SDSs. The employer can use web based SDSs as long as the employees have a community computer they can use to access the website at all times.
What are your other main points of concern in a detail bay? If an inspector walked into one of my customers tomorrow, absent a specific complaint, what would they be looking for?
Currently OSHA Region VIII has an emphasis program for automotive services. OSHA establishes emphasis programs when there are high rates of injuries and illnesses in a specific industry. When the compliance officer conducts an inspection in these industries, they are instructed to conduct a comprehensive inspection, meaning they are supposed to be looking at everything in the workplace. It is up to the discretion of the compliance officer to determine what they will be looking for. When I was conducting these inspections, I would walk through the entire facility. Here is a list of things I would typically look at. I am not saying this is a complete list, and this is not a legally binding answer (see the disclaimer below my signature).
OSHA 300 Logs
Hazard Communication (program, training, labeling, SDSs)
Automotive Lifts (conditions, inspections, training)
Electrical
Chemical Storage
Walking/Working Surfaces
Fall Hazards (4ft in general industry)
Emergency Exits and Routes
PPE (adequate and available)
Respiratory Hazards
Noise Hazards
OSHA’s Disclaimer to These Questions & Answers
It is our goal to work cooperatively with you to further workplace health and safety, and I trust that this information will be useful to you. However, please understand that this information is based on informal discussions without an opportunity to view your facility or operation. This document does not have the force and effect of law and is not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. It does not create (or diminish) legal obligations under the Occupational Safety and Health Act.
For more definitive guidance concerning the application of OSHA standards to a specific situation, condition, or hazard, you may request a formal interpretation from the Directorate of Enforcement Programs. Finally, OSHA may modify rules and related interpretations in light of new technology, information, or circumstances; to keep apprised of such developments or to review information on a wide range of occupational safety and health topics, please visit OSHA’s website at www.osha.gov.
Our Disclaimer
We are providing this information as is and cannot make any guarantees as to it’s accuracy. We have provided links to the resources so you can find the best current information. This information was accurate as of date of publication t the best of our knowledge but it is an interpretation by one OSHA employee.
