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Do You Have an Emergency Action Plan?

Did you know that OSHA requires businesses with 10 or more employees to have an Emergency Action Plan (EAP) for all types of emergencies such as chemical spills, fires, explosions, earthquakes, heavy weather, etc? As a matter of fact, OSHA has fined many auto repair shops for not having a written Emergency Action Plan prepared.

OSHA’s regulatory standard 29 CFR 1910.38 was primarily designed to protect your employees. A thoroughly prepared emergency action plan not only ensures that the workplace is as safe as possible, but reduces the danger for the surrounding community. To ensure you build an effective Emergency Action Plan, it is recommended that you familiarize yourself with its purpose and that your plan:

  • Is reviewed annually and updated to reflect any changes at the facility
  • Is clearly communicated to your employees
  • Includes all of the following:
    • Spill containment procedures
    • Evacuation plans
    • Alarm systems
    • Reporting procedures for personnel
    • Shutdown procedures
    • Types of potential emergencies

Following recommendations like these will help minimize risk and maximize workplace safety.

Of particular importance to service managers and shop foreman are the spill containment, cleanup, and reporting requirements. Shops must have a spill containment system capable of containing 100 percent of the volume of the largest material on hand. For example, if you have a 55-gallon drum of oil, your spill containment unit must be at least 55 gallons. You must also keep a record of spill activity in your shop. A common method of doing this is to fill out a Spill Report Form, a sample of which is available here. You are required to save these forms in a logbook or binder and must be made available to OSHA inspectors upon request. A good spill report form must contain the following information:

  • Date and time material was removed from spill containment area
  • Identity of material (an analysis is required if the spill is of unknown origin to determine the type of treatment or remediation required for proper disposal)
  • Quantity (volume)
  • Cause of spill
  • Method of disposal (includes transfer to off-site treatment system)
  • Corrective action implemented to prevent spills from reoccurring

In an effort to help Toyota and Lexus dealerships be prepared for spill containment and to comply with the OSHA regulation, Toyota provides two resources. First, we have provided a link to an easy-to-use Emergency Action Plan (EAP) template on OSHA's website. This template includes a step-by-step process to help a dealership set up an Emergency Action Plan. Second, Toyota has added environmental consumables as part of the Approved Dealer Equipment (ADE) program.

As you already know, ADE currently provides Toyota and Lexus dealerships with prescreened equipment and premier support services. To further strengthen this program, Toyota is expanding its offerings and providing dealers with a convenient source for everyday consumable products. This expansion includes a wide array of environmental management supplies to support Toyota’s “Earth Conscious” commitment.