Thursday, August 25, 2016

Bloodborne Pathogen Program



Imagine this scenario: At your car wash, an employee is cleaning the industrial vacuums while another is detailing the interior of a vehicle. One receives a cut from a needle, or some other sharp object, causing the other to rush to their aid. Are the injured worker and the person coming to their aid aware of the procedures in place to protect them from contracting an infectious disease? Are there even written procedures available? If not, your business is in violation of the OSHA standard for Bloodborne Pathogens 29 CRF 1910.1030.

Your wash’s documented procedures should establish a minimum set of rules to prevent exposure to bloodborne pathogens whenever an incident arises that may expose a worker to an unknown infection. They must also outline your company’s policy regarding who is authorized to respond to an incident where there might be exposure to a potentially infectious condition.

Bloodborne pathogens are defined as pathogenic microorganisms that are present in human blood and can cause disease. Two well-known examples are HIV and Hepatitis B. Bodily fluids are also included in this category since it is not always visibly possible to determine if there is the presence of contaminated blood.

OSHA requires that employers provide a written policy, acting as a communication of hazards, to every employee. Here are a few guidelines regarding the process:

  • Provide the policy when an employee first begins their job
  • Update the procedures whenever changes occur
  • Provide the written policy annually
  • Write the policy in terms and languages appropriate for comprehension from all employees
  • Make the Hepatitis B vaccine, as well as any appropriate medication associated with the disease, available to all employees. Include an option for any employee to opt out of this offer
  • A free post-exposure evaluation must be offered to employees
  • Perform a hazard assessment survey for the jobs where a bloodborne pathogen exposure may exist. Any PPE that is required as a result of this study must be made available to the employees. PPE must be usable and accessible to all employees. Make sure the equipment can be safely cleaned, or disposed of, and are replaced immediately when found to be unusable. Provide clear direction on how to safely dispose of any contaminated equipment and create a procedure to ensure the PPE has been properly removed from the site
  • Include an exposure control plan
  • Provide a specific training program
  • Develop an acceptance and declination form for Hepatitis B vaccinations and keep a copy on file.

If this seems like an overwhelming task to implement, there are a few free programs out there that offer training and can be a big assist to developing what you need.  Don’t delay, add this to your safety plan now!

Remember: A Safe Wash Protects People and Profits!

Thursday, May 26, 2016

Lockout/Tagout (LOTO)

Lockout/Tagout: Grim Consequences of Ignoring OSHA Standards


When it comes to working on car wash equipment at the wash, effective Lockout/Tagout (LOTO) procedures are crucial. Having these procedures in place not only complies with OSHA standards but, more importantly, can prevent serious injury or death.

For those of you that aren’t familiar with what a LOTO program is, review OSHA Subpart J, 29 CFR 1910.147 “The Control of Hazardous Energy.” This procedure establishes minimum standards for Lockout/Tagout at a facility. The goal of the program is the prevention of accidents caused by the unintentional energization of equipment or release of stored energy. An employee isolates an energy control device by applying a lock or tag to the device in the off, or safe, position, indicating that the control cannot be operated. Note that energy sources do not have to be electrical only. For instance, an air compressor would qualify as well.

The following are some headlines that provide real life examples of the consequences of not providing a proficient LOTO program at car wash locations:

  • A Car Wash Attendant Dies When Pulled Into a Side Arm Rotating Brush in a Car Wash - 2016
  • Jason’s Story: Electrocuted and Died in a Car Wash - 2014
  • Teen’s Leg Gets Stuck in Carwash Equipment – 2014
  • Car Wash Employee Gets Foot Caught in Conveyor - 2013
  • Man Loses Leg Cleaning Wash - 2011

Having a LOTO plan in place does not automatically mean that your car wash has all the components for compliance. Some of the owners in the cases above felt that they had protected their employees by implementing a LOTO plan. However, after investigating the circumstances behind a few of these incidents, it was learned that you can sometimes comply with the letter of the law, but not the spirit of the law. Case in point: In the first incident listed above, the car wash was missing a written procedure for safely performing the task that lead to the death. The employee may still be alive if the owner had taken into account other aspects and intentions of the LOTO program. The development of an audit and inspection program as part of the LOTO plan would have pointed out, in writing, the potential dangers of the procedure being performed by this individual. It would have educated the employee on the dangers associated with the job he was doing and why shutting down the power was necessary.


I recently read a Grainger article outlining a “Best Practice 5-Step Plan” that I believe will help bolster a LOTO program. It’s not just about having the locks, tags, signage and good intentions. The 5 steps are:

  1. Develop and document your energy control policy/program
  2. Create and post written, equipment-specific lockout procedures
  3. Identify and mark all energy control points
  4. Train your employees, communicate and conduct periodic inspections
  5. Equip your employees with the proper lockout tools and warning devices

It is important to note that the person who died in the first title above was performing a routine job. He was simply washing down the area around the conveyor where an excess amount of dirt and debris had accumulated. It was the process that killed this employee, not the actual hazard of this particular job!

It is human nature to take the position that we comply with regulations as well as anyone can be expected to. After all, we are responsible people doing the best we can to keep our employees safe. But, we also need to continue to question ourselves and keep an open mind to constantly evaluate if there is more we can do.  It is following the spirit of the laws that will truly keep our employees safe and alive.

Take another look at your LOTO program and decide if it will meet all the criteria necessary to protect your employees while working at the wash. If you don’t already have one in place, work with your insurance provider to get one. Do it today because tomorrow may be too late.


Remember: A Safe Wash Protects People and Profits!