OSHA Requirements for Auto Repair Shops

OSHA requirements create a legal obligation for auto repair shop owners and managers to meet various health and safety standards in the workplace.

About OSHA

The Occupational Safety and Health Administration (OSHA) was founded in 1970 within the United States Department of Labor. Its goal is to "assure safe and healthy working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance."

To achieve this goal, OSHA defines the safety requirements for various industries, inspects and imposes penalties on businesses for non-compliance, and provides training materials and consulting services to make compliance more readily achievable.

Who's responsible for OSHA compliance?

While much of the safety information we provide is intended for both shop management and technicians, OSHA compliance is the responsibility of shop management. The requirements set out by OSHA dictate the ways in which shop owners and managers are responsible for ensuring a safe working environment.

Fully understanding and complying with the numerous requirements set out by OSHA can feel like a daunting task. The information provided here is intended to do two things:

• Offer a high-level overview of the types of requirements that are involved
• Provide a strategy for ensuring full compliance despite the complexity involved

OSHA requirements for auto repair shops

Due to the number of requirements set forth by OSHA, it can be difficult to fully understand the topic. We'll address this issue later in the section titled "Strategy for OSHA compliance".

Generally speaking, OSHA's requirements fall into the following categories:

Hazard communication

OSHA requires that all employees who work with chemicals are informed about the possible hazards. Employees must also receive training for the safe handling of these chemicals.

The relevant requirements are set forth in the Hazard Communication Standard (29 CFR 1910.1200), which applies all businesses in the United States including auto repair shops.

Safety Data Sheets

A key tool for hazard communication is the Safety Data Sheet (SDS). Every hazardous chemical in a repair shop must have an SDS, and it must be stored somewhere employees can easily access.

The SDS provides critical information about chemical-based products, including:

• Identification and recommended use
• The potential hazards associated with the chemical
• Ingredient composition
• First aid measures to follow if exposure occurs
• Fire-fighting measures
• Accidental release measures
• Handling and storage
• Exposure controls and personal protective equipment (PPE)
• Physical and chemical properties
• Stability and reactivity
• Toxicological information
• Ecological information
• Disposal considerations
• Transport information
• Regulatory information
• Other information (revisions, notes, etc.)
• Labeling requirements

Containers of hazardous materials must be clearly labeled to indicate their contents and the potential hazards. While not as in-depth as an SDS, the label on a container serves as a prominent warning and a quick reference guide. The employee can refer to the SDS for more information as needed.

Employee training

All employees who interact or are responsible for chemicals in the shop must receive appropriate training. This includes:

• Reading and understanding an SDS
• The use of recommended personal protective equipment (PPE)
• Safe handling procedures
• Emergency / incident response protocols

Personal protective equipment (PPE)

All employers including auto repair shops are required to identify and furnish the proper PPE to their employees (29 CFR 1910.132). The PPE must be suitable for the work being performed, and employees must be trained on how to use it.

While employees must be trained in the need for PPE and how to use it, the employer is responsible for ensuring that it's used. Any liability associated with a failure to use PPE rests with the employer, including all OSHA enforcement actions and injury liability.

Eye and face protection

Many tasks in the shop require eye protection. It helps to mitigate hazards including flying debris, sparks, splashes, and mists. The type of eye protection used should be suitable for the work being performed and the specific risks involved (29 CFR 1910.133). OSHA provides eye protection standards for different tasks.

Hand protection

Gloves are an essential PPE item, and employers are required to furnish them as needed for employee safety (29 CFR 1910.138). They help protect workers' hands from burns, chemical exposure, and cuts.

Nitrile, neoprene, or butyl gloves are often used as they provide sufficient protection from many solvents and other chemicals. There are exceptions to this protection, so the SDS should always be consulted when using chemical-based products.

Leather gloves are required for welding (and may be useful for other heavy-duty tasks) because they provide greater protection against heat and sharp objects.

Hearing protection

OSHA defines noise exposure limits and requires employers to provide hearing protection to employees (29 CFR 1910.95).

Noise exposure is limited to below 85 decibels (dB) throughout an eight-hour workday. A second limit of 115 dB for shorter durations of up to 15 minutes also applies. For workplaces that exceed these limits, a hearing conservation program must be put in place.

The responsibility to provide appropriate hearing protection, and to ensure that employees use it, falls on the employer. Earplugs or other forms of hearing protection may be used depending on the noise level.

Paint technician protection

Paint technicians require specialized PPE due to the excess risk of airborne chemical exposure. All exposed skin should be covered when spray painting. This is achieved through the use of a protective hood and goggles combined with a full-body suit designed to be resistant to chemicals.

Respiratory protection program

Auto repair work can produce significant amounts of airborne chemicals and particulates that are hazardous to human health. It's the responsibility of employers to identify these hazards and provide PPE suitable for protecting against them (29 CFR 1910.134).

Respirators are mandatory while performing certain tasks like sanding, painting, and welding unless ventilation controls and other practices in the workplace have already reduced workers' exposure levels below the standards defined by OSHA's permissible exposure limits (PELs) (29 CFR 1910, Subpart Z).

Establish a respiratory protection program

Every shop needs a respiratory protection program, which is a detailed plan that includes:

• Clearly defined and documented procedures
• Appropriate selection of NIOSH-approved respirators suitable for the tasks performed
• Regular inspection and maintenance/replacement of respirators
• Employee training on when and how to use respirators
• Annual fit testing for employees who use respirators that require a proper seal
• Medical evaluations to determine the fitness of employees to use respirators
• Clear breathing air supplies where supplied-air respirators are used
• Ongoing risk assessment to detect respiratory hazards in the workplace

Even in shops where the exposure levels are within the PELs defined by OSHA, employees may opt to use respirators. In this scenario, a more limited respiratory protection program focused mainly on training and fit testing is acceptable.

Respirator type selection

To help determine the correct type of respirator based on various types of hazards, a quick guide is available from OSHA. A more detailed process for respirator selection is available from NIOSH.

It's the employer's responsibility to ensure that the type of respirator used is a correct match with the specific hazards and exposure levels that exist in the workplace.

Types of respirators include:

• Single strap dust masks typically aren't NIOSH-approved and are generally unsuitable for hazardous environments. The protection they offer is limited.
• Approved filtering dust masks / facepieces provide good protection from dust and mist but don't protect well against gas, vapor, asbestos, or lead exposure.
• Half-face respirators protect well against dust, mist, vapor, gas, and welding fumes. Filters must be matched to the specific contaminants and changed regularly.
• Full-face respirators offer similar protection to half-face respirators with additional coverage for the upper face and eyes. Filters must be matched to the specific contaminants and changed regularly.
• Powered-Air-Purifying Respirators (PAPR) utilize helmet or hood and a powered fan that draws in, filters, and circulates air. These respirators tend to be comfortable and can be used by people with facial hair. Filters must be matched to the specific contaminants and changed regularly.
• Self-Contained Breathing Apparatus (SCBA) systems provide a fully self-sufficient air supply and are suitable for use when the air quality (or lack of air) would pose an imminent threat to human health.

This video covers some commonly used respirator types:

Employee training and fit testing

Employees are required to undergo training on how to select, put on, and take off respirators. They should be aware of the limitations of various types of respirators and the need for proper respirator and filter selection.

Because a good seal is crucial to the protection a respirator provides, annual fit testing is required for employees who use tight-fitting respirators in their work. Facial hair must not be worn in a way that interferes with the ability of the respirator to seal to the face.

Medical evaluations for respirator users

Some medical conditions make patients unable to use respirators without a risk to their health. For this reason, employees whose work requires them to use respirators must been seen by a licensed healthcare provider to receive an assessment as to whether they're capable of using a respirator safely.

Electrical safety

Auto repair shops use a wide variety of tools and machines that require electricity, in addition to typical business needs (lights, computers, etc.). OSHA requires that shops and other businesses meet certain electrical safety standards (29 CFR 1910.303, ). Key areas of concern include design standards, safe work practices, and maintenance requirements.

Fire safety

Employers are required to take measures to prevent fires in the workplace. This includes having a fire prevention plan and sufficient fire extinguishers.

OSHA requires that a fire prevention plan must exist and be communicated to employees (29 CFR 1910.39). For employers with more than ten employees, the fire prevention plan must be documented in writing.

Among other things, the plan should identify the major fire hazards that exist in the shop, the equipment needed to mitigate each hazard, the potential ignition sources and how to control them, and procedures for handling and storing flammable materials.

There should be a specific individual or individuals who are named in the plan as being responsible for managing equipment, ignition sources, and flammable materials.

Employees must be made aware of fire hazards and any portions of the fire prevention plan that concern their safety. If the fire prevention plan involves employees using fire extinguishers, annual training should be provided on how to properly use a fire extinguisher and the risks involved when responding to a fire.

Fire extinguisher requirements

Portable fire extinguishers in good working order are required to promptly address any fires that may start, with certain exceptions (29 CFR 1910.157). The fire extinguishers must be OSHA-approved, fully charged, and regularly inspected. They should be located in places that employees can easily access in the event of a fire.

Flammable liquid storage cabinets

Storage cabinets used to hold flammable liquids are subject to OSHA regulations (29 CFR 1910.106). Flammable liquids must be kept separate from other chemicals and away from sunlight and heat sources. Storage areas should be prominently marked with the label "FLAMMABLE - KEEP FIRE AWAY".

Only certain cabinet designs are appropriate for use in storing flammable liquids. Approved fireproof cabinets are those built with 18-gauge or thicker sheet iron, double-wall construction with 1.25 inches of air space, and a door sill at least 2 inches higher than the cabinet's bottom edge.

OSHA specifies how much flammable liquid can be stored in a cabinet depending on the liquid's category:

• Category 1: Flashpoint below 73.4° F and boiling point at or below 95° F
• Category 2: Flashpoint below 73.4° F and boiling point above 95° F
• Category 3: Flashpoint at or above 73.4° F and boiling point at or below 140° F
• Category 4: Flashpoint above 140° F and boiling point at or below 199.4° F

A cabinet can store a maximum of 60 gallons of flammable liquids in Categories 1, 2, and 3. The maximum for Category 4 liquids in 120 gallons.

It's important that the containers of flammable liquid in a cabinet are easy to identify. All containers are required to be clearly labeled to indicate their contents, expiration dates, and any warnings from the manufacturer.

Flammable liquid storage rooms

Additional requirements apply to shops that have rooms dedicated to paint storage and/or mixing. These requirements primarily involve ventilation, electrical, and spill protection measures.

Emergency action plan

Every shop should have a well-defined plan for responding to emergencies and evacuating if necessary (29 CFR 1910.38). The plan should be specific to the shop and factor in its layout, structural elements, and other unique factors.

Employees should receive clear communication as to their roles and responsibilities under the emergency action plan. If your shop has more than ten employees, the emergency action plan must be documented in writing.

According to OSHA, the critical components of an emergency action plan include:

• A mechanism for reporting fires or other emergencies
• Procedures for evacuation including emergency escape routes
• Procedures for personnel who must execute critical operations before they evacuate
• Ensuring that all personnel are accounted for after an evacuation
• Any rescue or medical duties assigned to certain personnel
• Points of contact (names and/or job titles)

For more details about each of these requirements, OSHA provides an online guide.

Machine guarding

Shops are required to utilize safety guards on machinery where appropriate to minimize the risk of injury to employees (29 CFR 1910.212). Examples that apply to auto repair work may include:

• Locking mechanisms on automotive lifts
• Covers over moving parts on grinders and other tools
• Safety shields over machinery that produces flying debris
• Guards on tire changer machines to prevent pinching/crushing injuries

Machine guards must be regularly inspected and kept in good working order. Employees must also receive training on their use.

Lockout/tagout

Lockout/tagout (LOTO) helps to prevent injuries by disabling or tagging machinery during maintenance and repairs. The potential for machinery to cause injury is referred to as "hazardous energy," and LOTO protocols are designed to prevent the unexpected release of this energy.

A machine under lockout is physically prevented from starting up, and a machine under tagout is clearly marked so employees know it shouldn't be started up.

OSHA requires shops to implement LOTO protocols as needed to protect workers (29 CFR 1910.147). This includes various machinery used in the shop as well as the vehicles themselves.

Fleet Maintenance magazine has an excellent writeup covering the topic of LOTO as it relates to auto repair shops.

Workers' rights under OSHA

Workers in all industries including auto repair have the right to a safe working environment, including the right to:

• Receive training in workplace safety
• Use Personal Protective Equipment (PPE) that's appropriate for the job
• Refuse assignments in which hazards aren't appropriately guarded against
• Use machinery that's in safe working order
• Avoid exposure to toxic chemicals
• Report injuries/illnesses and access related medical records
• Access records documenting injuries/illnesses in the workplace
• View the results of any testing for hazards in the workplace
• Request an inspection by OSHA and communicate with the inspector

It's illegal to retaliate against an employee for reporting an issue to OSHA or requesting an OSHA inspection.

Strategy for OSHA compliance

It can be difficult for a shop owner or manager to fully comprehend the multitude of OSHA's requirements. While it's helpful to be familiar with the general principles and types of issues OSHA covers, it's best not to rely on memory or your personal understanding of the requirements. It's a big topic, and it can be easy to miss things.

Shop owners and managers would be wise to take advantage of OSHA's free, confidential on-site consultation program. An expert referred by OSHA will visit the shop in person and help identify areas that fall short of OSHA's requirements. This process is separate from OSHA's enforcement activities, and it won't trigger formal inspections or fines. It's a great way to ensure that you're compliant across the board.

Avoid OSHA-related scams

Scammers will take any opportunity to cheat someone out of their money, and the topic of OSHA requirements is no exception. You may be targeted by scammers who claim you need to buy labor law posters for your shop. The reality is that the posters are provided by OSHA on their website at no charge.

You may even be told that you've incurred a penalty for not displaying the posters, or threatened in some other way. These claims have no merit outside an official enforcement action by OSHA.

For more information, the Better Business Bureau has a good writeup about how to avoid the poster scam.